SolvedIFM29030 | Real Estate Investment Trust : Miscellaneous: indirect ownership of property: summary
From HM Revenue & Customs · Investment Funds Manual
This table summarises the treatment for different types of entity by reference to the various regime conditions and rules for a UK-REIT.
| Entity holding property | Income and gains | Property conditions | Balance of business |
|---|---|---|---|
| Member of REIT group | Company REIT: taxable within underlying entity; residual income when received by UK-REIT | Company REIT: Ignored | Company REIT : Value of shares / dividends comprise residual asset / income |
| Member of REIT group | Group REIT: Arising from qualifying property are tax exempt*** | Group REIT: Qualifying property counts | Group REIT : Line-by-line consolidation*** |
| Company with JV notice in place (see IFM30000) | Arising from qualifying property are tax exempt*** | Qualifying property counts | Line-by-line consolidation*** |
| AUTs and other non-transparent entities* | Taxable within the underlying entity and treated as residual income for tax purposes when received by the UK-REIT | Ignored | Company REIT or Group REIT interest ≤ 20% : Value of shares / dividends comprises residual asset / incomeGroup REIT : Interest > 20% : Line-by-line consolidation*** |
| Transparent entities** | Arising from qualifying property are tax exempt *** | Qualifying property counts | Company REIT: Value of assets held by entity and income arising to entity countGroup REIT : Interest > 20% : Line-by-line consolidation***Group REIT : Interest ≤ 20% : Value of shares / dividends comprise residual asset / income |
JV notice – Joint Venture notice in place
*includes OEICs
**including partnerships & overseas unit trusts – for more information on non-resident unit trusts, see IFM29040.
***to the extent of the group UK-REITs interest in the entity.