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HMRC internal manual

Guidance on Real Estate Investment Trusts

Leaving the regime: early exit



If an exiting company has been a UK-REIT or member of a Group REIT for less than ten years, the timing/ consequences of leaving may be different. If the company gives notice under section 571 CTA 2010 to leave the regime, then the tax treatment of property rental business assets sold within two years of leaving may be affected - see GREIT06040.


If the termination was by HMRC giving notice under section 572 CTA 2010, or automatic under section 578 CTA 2010 as a result of breaching conditions for company A, B E or F of section 528 CTA 2010, then the timing of leaving the regime and the tax consequences thereof can be altered by direction of HMRC - see GREIT06045.