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HMRC internal manual

Guidance on Real Estate Investment Trusts

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HM Revenue & Customs
Updated
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Distributions: attribution rules: first accounting period as a UK-REIT: example

Company joins the regime 1 January, normal accounting date 31 December

Company C has distributable reserves of 1,000 at 31 December 2006, the end of its finalpre- entry accounting period. In February 2007, C declares a final distribution for 2006of 800. This is all payable as a normal dividend. The pot of reserves brought forward is200, made up of (b) 150 ‘income from taxable activities’ and (e) 50‘other’.

In July, C declares an interim distribution of 650. To be sure of meeting the 90%requirement at the year end, C decides to pay 540 of the interim distribution, earmarkedas Category (a) (as a PID) and 110 as a normal dividend.

For its first accounting period as a UK-REIT, the year to 31 December 2007, the income ofC (tax-exempt) is 1000 and C (residual) is 100. C decides to pay a final distribution of400 in February 2008 and chooses not to attribute any of this to 2008 profits. No furtherdistributions are planned during 2008.

For the accounting period ending 31 December 2007, C must meet the 90% requirement byreference to the tax-exempt income of the whole period. For the full year, income of C(tax- exempt) is 1,000 and 100 for C (residual), so the total Category (a) in respect ofthat accounting period is 900. The total distributions paid from the start of theaccounting period to the CTSA filing date (31 December 2008) is 800 + 650 + 400. Of this,540 has already been paid as Category (a) so of the final distribution, 360 must beCategory (a).

C decides to attribute the remainder to (b) ‘income from taxable activities’, sopays a normal dividend of 40.

The pot of reserves carried forward is 250, and will be made up of (b) 100, (c) 100 and(e) 50.

Reconciliation for a.p.e. 31 December 2007

  reserves        
b/f February 2007 distribution July 2007      
distribution reserves        
c/f          
           
           
(a)     (540) (540)  
(b) 950 (800) (110) 40  
(c)       -  
(d)       -  
(e) 50     50  
           
totals 1,000 (800) (650) (450)  

Reconciliation for a.p.e. 31 December 2008

  reserves          
b/f adjustment to reserves b/f 2007        
profits 31.12.07          
final balance February 2008 distribution reserves c/f        
             
             
(a) (540)   900 360 (360) -
(b) 40   100 140 (40) 100
(c) -   100 100   100
(d) -     -   -
(e) 50     50   50
             
totals (450) - 1,100 650 (400) 250