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HMRC internal manual

Guidance on Real Estate Investment Trusts

From
HM Revenue & Customs
Updated
, see all updates

Distributions: 90% distribution requirement

 

A condition of remaining in the regime is that the company (principal company for aGroup REIT) must pay out 90% of the income profits of the tax-exempt business of eachaccounting period by the CTSA filing date for that period. That mandatory 90% is treatedas a PID.

If the company wants to distribute more to its shareholders, there are attribution rulesto determine how much of any additional distribution is from profits of the tax-exemptbusiness (and therefore payable as a PID under deduction of basic rate tax) or is out ofprofits that arose from taxable activities (and therefore treated as normal distributionswith no requirement to deduct tax on payment). The attribution rules are set out in GREIT08010 onwards.