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Contents

Official guidance
Investment Funds Manual

IFM23000 · Real Estate Investment Trust : Entry to the regime

  • IFM23005 · Overview
  • IFM23010 · Notice to join: CTA2010/S523 and S524
  • IFM23015 · Effects of entry: cessation of business and accounting period: CTA2010/S536
  • IFM23020 · Effects of entry: deemed sale and reacquisition of assets: CTA2010/S536
  • IFM23025 · Entry charge prior to 17th July 2012: outline
  • IFM23100 · Effects of entry: capital losses from pre-entry periods: CTA2010/S541
  • IFM23105 · Effects of entry: trading and other losses from pre-entry periods: CTA2010/S541
  • IFM23110 · Effects of entry: other expenses etc pre-entry periods: CTA2010/S541
  1. Real Estate Investment Trust : Entry to the regime: contents
  2. Real Estate Investment Trust : Entry to the regime: effects of entry: other expenses etc pre-entry periods: CTA2010/S541

IFM23110 | Real Estate Investment Trust : Entry to the regime: effects of entry: other expenses etc pre-entry periods: CTA2010/S541

From HM Revenue & Customs · Investment Funds Manual

The table below sets out the position for utilising expenses, deficits etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See The table below sets out the position for utilising expenses, deficits etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See for descriptions of terms used below.

Table 3: other expenses, losses etc

##### Description##### Type of loss etc##### Can be used against
Losses brought forward against certain investment incomeICTA1988/S393(8)Same type of investment income included in the residual business
Unused non-trading loan relationship and derivative contract deficitsCTA2009/S457 (financial instruments)Non-trading profits included in the residual business (even if deficit relates to financing costs etc of qualifying property business carried on pre-entry)
CVS loss reliefICTA1988/S573Investment companies only
Excess management expensesCTA2009/S1223Profits of the residual business (even if excess related to managing subsidiaries that operated qualifying property business pre-entry)
CAs for management of businessInvestment companies only
Unused non-trading losses on intangible fixed assetsFA2002/Sch29/Para35(3).Future profits of the residual business
Non-trade CAsFuture profits of the residual business
Excess charges paidICTA1988/S338(4)No carry forward (relief restricted to payments made in the accounting period)

See [The table below sets out the position for utilising expenses, deficits etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See The table below sets out the position for utilising expenses, deficits etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See for descriptions of terms used below.

Table 3: other expenses, losses etc

##### Description##### Type of loss etc##### Can be used against
Losses brought forward against certain investment incomeICTA1988/S393(8)Same type of investment income included in the residual business
Unused non-trading loan relationship and derivative contract deficitsCTA2009/S457 (financial instruments)Non-trading profits included in the residual business (even if deficit relates to financing costs etc of qualifying property business carried on pre-entry)
CVS loss reliefICTA1988/S573Investment companies only
Excess management expensesCTA2009/S1223Profits of the residual business (even if excess related to managing subsidiaries that operated qualifying property business pre-entry)
CAs for management of businessInvestment companies only
Unused non-trading losses on intangible fixed assetsFA2002/Sch29/Para35(3).Future profits of the residual business
Non-trade CAsFuture profits of the residual business
Excess charges paidICTA1988/S338(4)No carry forward (relief restricted to payments made in the accounting period)

See](https://www.gov.uk/hmrc-internal-manuals/investment-funds/ifm23100) and [The table below sets out the position for utilising expenses, deficits etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See The table below sets out the position for utilising expenses, deficits etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See for descriptions of terms used below.

Table 3: other expenses, losses etc

##### Description##### Type of loss etc##### Can be used against
Losses brought forward against certain investment incomeICTA1988/S393(8)Same type of investment income included in the residual business
Unused non-trading loan relationship and derivative contract deficitsCTA2009/S457 (financial instruments)Non-trading profits included in the residual business (even if deficit relates to financing costs etc of qualifying property business carried on pre-entry)
CVS loss reliefICTA1988/S573Investment companies only
Excess management expensesCTA2009/S1223Profits of the residual business (even if excess related to managing subsidiaries that operated qualifying property business pre-entry)
CAs for management of businessInvestment companies only
Unused non-trading losses on intangible fixed assetsFA2002/Sch29/Para35(3).Future profits of the residual business
Non-trade CAsFuture profits of the residual business
Excess charges paidICTA1988/S338(4)No carry forward (relief restricted to payments made in the accounting period)

See [The table below sets out the position for utilising expenses, deficits etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See The table below sets out the position for utilising expenses, deficits etc arising in accounting periods up to the date the REIT rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief. See for descriptions of terms used below.

Table 3: other expenses, losses etc

##### Description##### Type of loss etc##### Can be used against
Losses brought forward against certain investment incomeICTA1988/S393(8)Same type of investment income included in the residual business
Unused non-trading loan relationship and derivative contract deficitsCTA2009/S457 (financial instruments)Non-trading profits included in the residual business (even if deficit relates to financing costs etc of qualifying property business carried on pre-entry)
CVS loss reliefICTA1988/S573Investment companies only
Excess management expensesCTA2009/S1223Profits of the residual business (even if excess related to managing subsidiaries that operated qualifying property business pre-entry)
CAs for management of businessInvestment companies only
Unused non-trading losses on intangible fixed assetsFA2002/Sch29/Para35(3).Future profits of the residual business
Non-trade CAsFuture profits of the residual business
Excess charges paidICTA1988/S338(4)No carry forward (relief restricted to payments made in the accounting period)

See](https://www.gov.uk/hmrc-internal-manuals/investment-funds/ifm23100) and](https://www.gov.uk/hmrc-internal-manuals/investment-funds/ifm23105) for Tables 1 and 2: capital and trading losses etc.

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