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HMRC internal manual

Company Taxation Manual

AIFs: Property authorised investment funds (Property AIFs): tax treatment of distributions in the hands of participants: introduction

In accordance with the principles set out at CTM48811distributions made by a Property AIF must be split into three pools.

The Financial Services Authority rules that apply to all types of authorised investmentfunds require a Property AIF must distribute all of its net income. CTM48852sets out the rules which must be followed in allocating the income of the Property AIF toeach type of distribution.

General principles for the taxation of property income distributions are set out at CTM48852.

The tax treatment of each type of distribution in the hands of different participants isset out in the following pages as follows:

  • participants within the charge to CT (generally companies) - CTM48853.
  • participants within the charge to IT (generally individuals) - CTM48854 to CTM48857.
  • Non-resident participants - CTM48858.