Non-UK resident companies that buy, develop, or sell UK land must register for Corporation Tax within three months of a disposal.

Those non-UK resident companies that deal in or develop UK land must register for Corporation Tax if their activities involve acquiring or developing property with the intention to profit from its disposal. This requirement applies when the land is held as trading stock, or when a main purpose of acquiring or developing land is to sell it for profit. This is different from acquiring property for investment purposes, such as rental income.

Companies are required to register within three months of making a disposal of UK land. The registration process involves providing essential details, including the company name, country of incorporation, registration number, addresses (both the registered office and the UK business address) and the date the company became liable to Corporation Tax. If the company is part of a group, details of the parent company must also be provided.

Registration can be completed online, after which companies must print and submit the form to HMRC. Alternatively, if online registration is not possible, companies can send a letter with the required information, including a 10-digit dummy Unique Taxpayer Reference (UTR). Once HMRC processes the registration, the company will receive its Corporation Tax UTR.

Paying Corporation Tax? Always use the correct reference or risk delays and penalties.

To pay Corporation Tax via online or telephone bank transfer, you can use either a UK or overseas bank account.

UK Bank Accounts

You can transfer funds using Faster Payments, CHAPS, or Bacs, either online or by calling your bank. Faster Payments usually reach HMRC on the same or next day (including weekends), CHAPS payments arrive the same working day if made within your bank’s cut-off time, and Bacs payments typically take up to 3 working days.

Use the account details provided in your HMRC ‘notice to deliver your tax return’ or reminder. If unsure, use one of the following:

• HMRC Cumbernauld
  • Sort code: 08 32 10
  • Account number: 12001039
• HMRC Shipley
  • Sort code: 08 32 10
  • Account number: 12001020

Overseas Bank Accounts

You can also pay from an overseas account using:

• HMRC Cumbernauld
  • IBAN: GB62 BARC 2011 4770 2976 90
  • BIC: BARCGB22
• HMRC Shipley
  • IBAN: GB03 BARC 2011 4783 9776 92
  • BIC: BARCGB22

You must ensure to include your 17-character Corporation Tax payment reference number for the correct accounting period. This reference changes each year so it is important to use the up-to-date reference number. Using the wrong one can delay your payment. You can find it in your company’s HMRC online account or on your ‘notice to deliver your tax return’ or on any reminders from HMRC.

With a £50bn shortfall looming, the Chancellor may need to revisit last year’s Corporation Tax roadmap commitments.

As this year’s Autumn Budget approaches, it is an interesting time to revisit the Corporation Tax Roadmap published alongside last year’s Budget on 30 October 2024.

The roadmap sets out the government’s plans for Corporation Tax and a small number of other business taxes over the course of the parliament.

These commitments included:

• Capping the headline rate of Corporation Tax at 25% for the duration of parliament, the lowest rate in the G7.
• Retaining the small profits rate and marginal relief at current rates and thresholds.
• Maintaining the capital allowances system, including permanent full expensing and the £1 million annual investment allowance.
• Maintaining the generosity of R&D reliefs.
• Collaborating with companies on simplification and improving user experience, including HMRC’s path forward on digitisation.
• Developing a new process for increasing the tax certainty available in advance for major investments.

Almost a year later, the Chancellor is facing a significant budget shortfall that could be as high as £50 billion, driven by multiple issues including weak growth, persistent inflation, high debt interest costs and widening deficits.

The government has also committed not to raise income tax, National Insurance or VAT for working people, and to restore frozen tax thresholds in line with inflation from 2028–29.

It remains to be seen whether any of the major commitments outlined in the roadmap and in previous promises to the voting public will be rolled back.

New UK transfer pricing rules could mean more reporting and fewer exemptions for mid-sized businesses. The government is consulting on proposals to tighten compliance and align with global standards. One key change would remove the transfer pricing exemption for medium-sized enterprises, keeping it only for small businesses. Another would introduce a new reporting requirement, the International Controlled Transactions Schedule (ICTS), to give HMRC more visibility over cross-border related-party transactions. These reforms aim to curb profit shifting, protect the UK tax base and simplify the rules for those who follow them.

Transfer pricing refers to how prices are set for transactions between companies that are part of the same group, especially when these transactions cross international borders. These prices must follow the “arm’s length principle,” meaning they should reflect what unrelated companies would charge under similar circumstances. This helps ensure that profits are taxed fairly where economic activity actually takes place.

The UK government is seeking feedback on two proposed changes to its transfer pricing rules. These proposals aim to protect the UK’s tax base from multinational enterprises (MNEs) shifting profits overseas, and to bring the UK in line with global best practices.

The first proposal suggests changing the current exemption from transfer pricing rules for small and medium-sized businesses (SMEs). In particular, it proposes removing the exemption for medium-sized enterprises but keeping it for small ones. The government also wants to update definitions and thresholds to make the rules clearer and easier to follow.

The second proposal would introduce a new reporting requirement called the International Controlled Transactions Schedule (ICTS). This would require MNEs to report cross-border related-party transactions to HMRC. The information would help HMRC better assess risk, reduce audit times, and support fairer, more efficient tax compliance whilst at the same time limiting extra burdens on businesses.

Corporation Tax rises with profit levels. Marginal relief bridges the gap, easing businesses from the 19% small profits rate to the 25% main rate.

The Corporation Tax Main Rate applies to companies with profits exceeding £250,000 and is currently set at 25%. For companies with profits up to £50,000, a Small Profit Rate (SPR) of 19% is applicable.

For profits between £50,000 and £250,000, a marginal rate of Corporation Tax is used to smooth the transition between the lower and upper limits. The lower and upper thresholds are also adjusted proportionately for short accounting periods of less than 12 months and for companies with associated entities.

Marginal relief gradually increases the effective Corporation Tax rate from 19% at profits of £50,000 to 25% at profits over £250,000. To calculate the Corporation Tax due, you multiply your profits by the main rate of 25% and subtract the marginal relief. For the current 2025 fiscal year, the marginal relief fraction is 3/200.