CFM97750 | Interest restriction: property and REITs: REITs and the interest restriction return

TIOPA10/S452(11)

The normal reporting rules for CIR apply to REITs.

In addition, where an interest restriction return (IRR) is made in relation to a UK REIT group carrying on PRB and residual business, it must be made clear how TIOPA10/S452 has been applied.

In particular, under the CIR rules, the PRB and residual business of each company are treated as separate members of the same CIR worldwide group (referred to as the PRB company and residual business company, respectively).

In practice, this means that the IRR should show separate entries for the PRB companies and the residual business companies. In particular, the statement of allocation of disallowances should show the amounts allocated to the PRB company and to the residual business company of each actual company. Further supplementary explanation may be appropriate.