Residential property developer tax (RPDT)

Produced by Tolley in association with of Crane Dale Tax, part of AMS Group

Corporation Tax

Guidance

Residential Property Developer Tax (RPDT) applies to certain profits from UK residential development activity, as part of its Building Safety Programme arising from the Grenfell tragedy.

In broad summary, RPDT applies to UK resident companies and non-resident companies within the charge to UK corporation tax (such as those that have a UK permanent establishment) that:

•
-generate profits from land held as trading stock for residential property development, and
•
have relevant profits in excess of £25m

FA 2022, s 34; RPDT10100

Companies will be within the scope of the rules where they undertake residential property development activities in respect of UK land in which they, or a related company, have or have had an interest, provided that interest forms, or formed, part of trading stock. Property investment companies (including those using a build-to-rent model) are therefore excluded from the remit of the regime.

Broadly, trading profits for RPDT are calculated as for corporation tax, but with some significant adjustments. For example, loan relationship

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Rob Durrant-Walker

Tax Director at Crane Dale Tax , Corporate Tax, OMB, Personal Tax

Rob is a cross-tax advisor with a particular focus on property tax planning, and business structure planning for OMB’s. He provides tax advice to other accounting firms, balancing commerciality, ethics, and understanding complexity. His 30+ years of experience start at the Inland Revenue in Hull. After completing his ATT and CTA by 1999 with PKF, he subsequently worked at KPMG and UHY prior to managing the business tax team as a director at Garbutt + Elliott. Rob is now Tax Director at the independent tax consultancy, Crane Dale Tax. He is a regular author for Taxation magazine with many articles and Readers Forum contributions since 2005, and he contributes as a virtual member to the CIOT Property Tax technical committee. Rob works remotely from Vancouver in Canada.

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Residential property developer tax (RPDT)