French property income and LMNP regime

Hi, I was wondering what was the UK tax treatment (for a UK resident) of property income from France, which is declared there under the LMNP scheme. The LMNP scheme is a company-like regime, which has a business registration number (SIRET) and files full company accounts every year. The specific type of company (EI) is not covered in the transparent / non-transparent entity list on HMRC website, hence my question. The French authority provide a statement, to the attention of foreign tax administrations, stating that the company is resident of France. Under the double tax treaty, companies are to be taxed in the country of incorporation / place of business, which is France in this instance. Would HMRC agreed that such company income is not subject to UK tax liability, as long as the benefit is not distributed? Thank you

Hi,
You should declare all income received worldwide on your UK return.
Any tax paid in foreign companies should be claimed back under the double taxation provisions.
Thank you.

Hi, I believe that as a UK resident, if I own Company A abroad, that HMRC classifies this type as opaque, that this companies makes a profit which is not distributed (i.e. no dividends), nothing is reportable in the U.K. Kindly correct me if the above is wrong. My question is: what is HMRC position on the company type i described first, opaque or transparent (not in the official list). Thank you

Hi Adrien777,
HMRC will provide a view of whether we consider a particular foreign entity to be transparent or opaque in specific cases. 
Details of how to make an application can be found at:-
INTM180020 - Foreign entity classification for UK tax purposes: Considerations when using the List of Classifications of Foreign Entities for UK tax purposes
Thank you.