IFM05410 - Investors in property authorised investment funds (PAIFs): investors within the charge to corporation tax: Property income distributions (PIDs)

For corporate tax payers, under regulation 69Z18 SI 2006/964, PIDs are generally charged to corporation tax as profits of a property rental business. This is unlike normal company distributions, which are exempt from tax in the hands of most UK companies. The PID will, in general, be paid without deduction of tax to persons within the charge to UK corporation tax (regulation 69Z24 SI 2006/964).

The exception to that treatment is where the recipient is a member of Lloyd’s or a financial trader, when the PID is treated as a receipt of their trade.