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Posted Tue, 16 Apr 2024 11:01:53 GMT by Clara Li
Hi, I have two questions regarding interest deduction and tax depreciation of properties. I understand that the deductibility of interest expense is subject to numbers of rules, including hybrid mismatch. The scenario is as follows: There is a small UK company that is deriving rental income from its investment properties in UK (residential properties). The company incurs interest expenses on its shareholder loans that are provided by non-resident individual shareholders (Hong Kong). In Hong Kong, the foreign sourced interest income is not taxable on the basis that Hong Kong adopts the "territory source principle" on the interest income derived by individuals. Only Hong Kong sourced interest income will be subject to tax in HK. In this case, is the interest expense incurred by the UK company deductible from the perspective of the hybrid mismatch (assuming it is not subject to other interest deduction rules, e.g. thin cap rules ,etc.) Further, is the company eligible to any capital allowance or tax depreciation deduction on the investment properties (residential properties in UK)? May I know the relevant tax rules? I heard some people say the UK residential properties are not subject to (accounting) depreciation and no valuation is required because it is a small company. So the company should have no accounting depreciation as well as capital allowance/ tax depreciation deduction on the residential properties. Is it true? Thank you so much.
Posted Mon, 29 Apr 2024 14:06:43 GMT by HMRC Admin 17
Hi ,
I cannot give definitive answer as we do not give tax planning advise, you may need to speak to a financial/tax advisor.
Please review the guidance at, and, this should help you identify
if the property your company owns can claim capital allowances.

If you have any issues deciding if your property can be included, then you should seek assistance for a financial/tax advisor.

Thank you .

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