IFM07300 | Investors in tax elected funds (TEFs): TEF distributions (dividends) - investors within the charge to corporation tax

Treatment of property investment income within the corporate streaming rules (regulations 48 to 52A SI2006/964)

Special treatment is provided for dividend distributions in the hands of investors in authorised investment funds (AIFs) when they are within the charge to CT.

This treatment (known as “corporate streaming”) is contained in regulations 48 to 50 of SI2006/964 with modifications for TEFs in regulation 69Z62 – see IFM03320. Where property investment, property business income or non-exempt dividends are received and distributed as a TEF distribution (dividend) to investors within the charge to CT, then under regulation 69Z57(2) of SI2006/964, any unfranked part of the distribution should be treated as annual payment.