NRL2 and NRL3: Gross Payment Applications for Companies and Trusts

Individual non-resident landlords apply for gross payment approval using Form NRL1. But if your UK property is owned through a company or trust structure, the application route is different — companies use Form NRL2, and trusts use Form NRL3.

Form NRL2: Non-Resident Corporate Landlords

NRL2 is the application for a non-resident company landlord to receive UK rental income without tax deducted at source. The company must be incorporated outside the UK, have no place of business in the UK, and not be regarded as UK-resident for tax purposes.

The application requires the company's registration number, country of incorporation, registered office address, Unique Taxpayer Reference (UTR), and details of each UK property owned. Apply online through Government Gateway or complete and post the NRL2 form to HMRC. If applying through a tax agent, use the postal route and include Form 64-8.

There is one important exception: a foreign-incorporated company that is UK tax-resident (because its central management is actually in the UK) or that operates through a UK permanent establishment already falls outside the NRLS withholding rules. These companies are treated as having a UK usual place of abode and don't need NRL2 — their UK rental income is taxed under standard Corporation Tax instead.

Non-resident corporate landlords pay UK Corporation Tax rather than Income Tax on their rental profits. They file an annual CT600 return electronically via iXBRL software. Tax withheld under the NRLS before gross approval was granted can be set off against the company's total Corporation Tax liability.

Form NRL3: Non-Resident Trustees

NRL3 is the equivalent application for trusts. It requires the trust's reference number, UTR, the names and addresses of all trustees, and the UK property details. Trustees can apply online or use the postal NRL3 form; if applying through a tax agent, use the postal route with Form 64-8.

The scheme applies to a trust only when every trustee has a usual place of abode outside the UK. If even one trustee lives in the UK, the trustees as a group fall outside the NRLS withholding rules — though they still have standard UK trust tax return filing obligations.

This all-or-nothing rule has a practical consequence: adding a UK-resident trustee to a trust removes it from the NRLS entirely. Some trust arrangements deliberately include a UK-resident trustee for this reason, though doing so has broader trust administration implications that go beyond the NRLS.

Non-resident trustees file under the Trust and Estate Self Assessment regime using Form SA900.

How Corporate and Trust Applications Differ From NRL1

The approval mechanics are otherwise identical: HMRC processes the application (typically 2–4 weeks), issues an NRL8 approval notice to both the applicant and the letting agent, and normally dates the authority to pay gross from the first day of the quarter in which the application was received.

For these applications, HMRC considers whether the information is correct and whether the applicant will follow their UK tax obligations.

When Structure Matters

Whether you hold UK property personally, through a company, or via a trust affects not just the NRLS application form but the entire tax reporting framework — Corporation Tax rates versus Income Tax rates, different filing forms, different expense rules, and different treatment of mortgage interest. The NRLS application is a small piece of a larger structural question.

Our Non-Resident Landlord Scheme guide covers the NRL1 individual route in full detail (including the agent-change protocol and SA109 filing roadmap), plus the key differences for company and trust structures — so you can map the right form to your ownership arrangement.

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