Foreign equivalents to UK-REITs

List of foreign structures that are considered by HM Revenue and Customs to be equivalents to UK-REITs.


Where a Property Authorised Investment Fund (Property AIF) owns shares in foreign entities equivalent to UK Real Estate Investment Trusts (UK-REITs), then these shares will be classed as assets of a property investment business. As specified in CTM48814 of the Property AIF guidance, please find below a list of foreign structures that are considered by HM Revenue and Customs (HMRC) to be equivalent to UK-REITs for the purposes of Regulation 69G of the Authorised Investment Funds (Tax) regulations 2006 (SI 2006/964).


This list is not likely to be exhaustive and will be updated once further foreign structures are identified as meeting the criteria set out in CTM48814.

Structures in List A are considered to meet all the criteria.

Structures in List B may sometimes meet the criteria. For example, if the jurisdiction allows the structure to be open-ended (having variable share capital) or to be closed-ended (having defined share capital) then providing that the rules for the structure met all other criteria those that were closed-ended would be equivalent to UK-REITs.

Lists last updated on 2 June 2006

List A: Foreign entities equivalent to UK-REITs

Country Structure
Belgium Société d’investissement à capital fixe en immobilière
Germany G-REIT
Israel REIF
Italy Società d’Intermediazione Immobiliari Quotate

Where it is considered that a further foreign structure fulfils all the criteria to be treated as equivalent to a UK-REIT, then details can be sent to HMRC:

Attn: Eric McLennan
Authorised Investments Funds Centre
HMRC Local Compliance Eastern England
Concept House
5 Young Street
S1 4LB

The details should show why the structure meets the criteria and provide references to relevant foreign legislation.

List B: Foreign entities that may be equivalent to UK-REITs in some circumstances

The structures below will only qualify where they have defined share capital and the market in shares or units is by way of a listing on a recognised stock exchange. Collective investment schemes (such as Property AIFs) where the investor has a right of redemption do not qualify. In some cases there are also other conditions that must be met as indicated below.

Country Structure Further conditions
Australia Listed Property Trust Unit holders must be entitled to income at year end and consequently trustee not liable to taxation. Income and assets min 75 per cent real property
Bulgaria JSSPIC (Joint Stock Special Purpose Investment Company) US-REIT Must be a SPIC investing in real estate property
Published 12 June 2008