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HMRC internal manual

Guidance on Real Estate Investment Trusts

Group conditions and rules: Financial Statements: G (tax- exempt): entities that are not wholly owned

Joint venture companies

A group may be involved in a joint venture carried on via a company. If there is aJoint Venture Look-Through notice in place (see GREIT13015),then the group (referred to as the venturing group) includes the profits etc of the jointventure company in the financial statements for G (tax-exempt) in the same way as it doesfor the same items for companies that are members of the venturing group (regulation 12 SI2006/2866).

Other entities in which the group has an interest

If the entity is transparent for tax purposes (e.g. a UK partnership), the group’sshare of the profits etc to the extent they derive from qualifying property rentalbusiness, are included in the financial statements for G (tax-exempt).

If the vehicle is not transparent (e.g. a company that is less than 75% owned or an OEIC)then will be no entries in connection with it in the financial statements for G(tax-exempt).

The value of the interest in the entity and in any income arising from that interest willbe part of G (residual).