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HMRC internal manual

Guidance on Real Estate Investment Trusts

Miscellaneous: indirect ownership of property: summary for single company REITs

 

This table summarises the treatment for different types of entity by reference to thevarious regime conditions and rules for a single company REIT. For Group REITs, see GREIT09030.

Entity holding property Income & gains Property conditions Balance of business Entry Charge
         
Member of TCGA group Taxable Ignored Value of shares /dividends non ring-fence asset /income Not applicable
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 Value of shares /dividends non ring-fence asset /income Not applicable
Transparent entities** owned by UK-REIT itself Arising from qualifying property are tax-exempt Unlikely to count Value of assets held by entity and income arising to entity count Market value of qualifying property
Transparent entities** owned UK-REIT subsidiary Taxable Ignored Property and income included in value of subsidiary Not applicable

*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 and gains arise to C (tax-exempt) and theEntry Charge arises to C (residual).

For a joint venture company with a JVLT notice in place, the Entry Charge is payable bythe joint venture company.