IFM02340 - Excess financing costs in a qualified investor scheme (QIS) which is a property authorised investment fund (PAIF)
There are special rules that apply to PAIFs that are QIS which reduce the scope for extracting profits of the tax-exempt business as interest instead of property income distributions. The reason that there is no need for a similar tax rule for other PAIFs is that the Financial Conduct Authority restricts their borrowing to reduce risk to the investors. See IFM04350 for details.