Between 29 November and 6 December 2016, new protocols amending the UK/Jersey, UK/ Guernsey and UK/Isle of Man double tax treaties came into force (each taking effect from 16 March 2016).

This follows the 2016 Budget announcement that, from 16 March 2016, non-UK residents who realise profits from either (i) trading in UK land, or (ii) developing UK land with a view to selling it, will be subject to UK corporation tax on such profits. This will be the case regardless of whether the non-UK resident has a UK permanent establishment.

The amendments put beyond doubt that the UK has taxing rights over these transactions involving UK land.

The protocols can be viewed here, here and here.