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HMRC internal manual

Guidance on Real Estate Investment Trusts

From
HM Revenue & Customs
Updated
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Miscellaneous: indirect ownership of property: summary for Group REITs

 

This table summarises the treatment for different types of entity by reference to thevarious regime conditions and rules for a Group REIT. For single company UK-REITs, see GREIT09035.

Entity holding property Income and gains Property conditions Balance of business Entry Charge
         
Member of TCGA group Arising from qualifying property are tax-exempt Qualifying property counts Line-by-line consolidation Market value of qualifying property
Company with JVLT notice in place (see GREIT13000) Arising from qualifying property are tax-exempt Qualifying property counts Line-by-line consolidation Market value of qualifying property
AUTs and other non-transparent entities* Taxable Ignored I > 20%  
Line-by-line consolidation Not applicable      
I = 20%        
Value of shares /dividends non ring-fence asset /income        
  Transparent entities** Arising from qualifying property are tax-exempt Unlikely to count I > > 20%
Line-by-line consolidation Market value of qualifying property      
  I = 20%      
Value of shares /dividends non ring-fence asset /income

*includes companies that are not members of the TCGA group, such as OEICs

**including partnerships & overseas unit trusts – for more information onnon-resident unit trusts, see GREIT09040.

For transparent entities, the tax-exempt income, gains and the Entry Charge arise to themembers of the group which have an interest in the entity.

For other entities, such as a member of a TCGA group or a joint venture company, the EntryCharge is payable by the entity itself.