Non-resident landlords (NRL) are subject to the Non-Resident Landlords Scheme (NRLS). Although the UK does not generally tax non-residents (see the Residence of companies guidance note), it does apply tax in respect of UK source income, and in particular in respect of rental income from UK properties.
Without special provisions, non-UK resident landlords could evade the UK tax charge by virtue of their absence and non-declaration of this income. While there is officially no withholding tax per se on the payment of rental income to an NRL, the NRLS requires an effective withholding tax to be deducted by either the tenant or letting agent, as appropriate, unless the landlord obtains permission from HMRC to receive the rental income gross. It is therefore necessary to consider: