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United Kingdom
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Non-resident landlords scheme (NRLS) meaning

What does Non-resident landlords scheme (NRLS) mean?
HMRC’s Non‑resident Landlords Scheme (NRLS) is the UK withholding regime used in property practice to collect tax on rent paid to landlords who are not UK‑resident for tax. Letting agents—and, where no agent acts, tenants paying more than £100 per week—must deduct income tax at the basic rate from rents arising from a UK property business and account for it to HMRC, unless HMRC has authorised payment of rent gross. The deduction gives the landlord a credit against their UK tax liability (income tax for individuals and trustees, or corporation tax for non‑resident companies). The scheme is provided for in legislation, principally the Income Tax (Non‑resident Landlords) Regulations 1995, and is administered consistently across England & Wales, Scotland and Northern Ireland. It applies to individuals, companies and trustees and carries registration, withholding, payment and reporting obligations for letting agents and certain tenants. In Ireland, a separate statutory regime—Non‑Resident Landlord Withholding Tax—applies and the NRLS terminology is not used. Practically significant for: drafting and negotiating rent payment clauses, advising letting agents and tenants on compliance, and tax due diligence where landlords are non‑resident. Search terms: non‑resident landlord tax, HMRC NRLS, withholding on UK rent, pay rent gross approval.
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View the related Practice Notes about Non-resident landlords scheme (NRLS)

PRACTICE NOTES
UK taxation of non-UK resident companies: permanent establishments, UK property income and gains, continental shelf oil and gas, income tax, DPT/UTPP, and double tax treaties

Stop Press: Section 49 and Schedule 7 of the Finance Act 2026 amend the UK’s domestic legislation concerning UK permanent establishments of non-UK companies, taking effect for accounting periods (in respect of corporation tax) or tax years (for income tax) that begin on or after 1 January 2026, respectively. In each case, the measures adjust both the definition of a UK permanent establishment and the rules for attributing profits to a UK permanent establishment, so as to bring them nearer into line with the OECD Model Tax Convention, from that date and thereafter in UK law. Section 46 and Schedule 5 of the Finance Act 2026 provide for the abolition of the DPT regime and its replacement by the ‘unassessed transfer pricing profits’ (UTPP) rules, effective for accounting periods commencing on or after 1 January 2026. HMRC has inserted a new chapter within the HMRC International Manual containing guidance on the UTPP rules at INTM489100. For more information about these changes, see News Analysis: Budget 2025—Tax analysis —...

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