Non-resident company landlords (NRCLs) brought within the scope of Corporation Tax - outstanding CT UTRs

We have received an update from HMRC in relation to the non-receipt of a HMRC letter advising the NRCL of their CT UTR.

At the end of January/early February 2020, HMRC sent out letters advising non-resident company landlords of their CT UTR. Agent Update 77 set out the action an agent of the NRCL could take once 30 June 2020 had passed (see extract below). HMRC note they cannot issue details of the CT UTR to an agent without the signed 64-8 authority. If the agent has already written in, the request will be dealt with as soon as possible but COVID-19 has had a major effect on response times. In addition, although HMRC initially indicated they could accept bulk applications, since staff are now working remotely due to COVID-19, HMRC would now prefer individual requests to be made and apologise for any inconvenience caused.

Where the UK property business  started after 6 April 2018, it would not be on the database used in the automatic process for allocating CT UTRs. HMRC set out in Agent Update 76 they would write separately to those NRCLs that did not file a tax return for 2017-18 when HMRC dealt with their 2018-19 SA700. It would therefore take a little longer to write to these companies. However, again due to COVID-19, the workload of the HMRC Non-residents Landlord team had to be re-prioritised. More recently, the team’s work plans have been re-visited and staff have been allocated to this task as a priority.

Extract from Agent Update 77
Corporation Tax Unique Tax Reference Agent Authority 64-8

On 6 April 2020, the profits or UK property income from UK property businesses of over 20,000 non-resident company landlords were brought within the scope of Corporation Tax.

We have written to the majority of these companies to let them know their Corporation Tax Unique Tax Reference (CT UTR) and the action needed to be taken by them. However, we have had feedback that some letters have not yet been received. Since the existing 64-8 agent authority does not extend to Corporation Tax, we cannot advise the company’s agent of the CT UTR for their client.

We expect that all letters should be received by 30 June 2020. Unless your client needs to file a CT return before this date, we ask that you do not contact HMRC. Should you need to file a CT return by 30 June 2020, please provide HMRC with a new signed 64-8 agent authority for Corporation Tax, together with a covering letter. You should quote the SA UTR on the covering letter but leave the space for the UTR on the new 64-8 blank.

Please send your letter and 64-8 agent authority to:

Charities, Savings and International 1
HM Revenue and Customs
BX9 1AU

If your client has not received their letter by 30 June 2020, please take the same action as above.