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HMRC internal manual

Investment Funds Manual

Investors in property authorised investment funds (PAIFs): introduction

In accordance with the principles set out at IFM04110 distributions made by a PAIF must be split into three pools.

IFM05300 sets out the rules which must be followed in allocating the income of the PAIF to each type of distribution.

The tax treatment of each type of distribution in the hands of different investors is set out in the following pages as follows:

  • Investors within the charge to CT (generally companies) - IFM05400.
  • Investors within the charge to IT (generally individuals) - IFM05510 to IFM05540.
  • Non-resident investors - IFM05600.