IFM28030 - Real Estate Investment Trust : Distributions: attribution rules: category (c) - other income of the property rental business: CTA2010/S550(2)(c)

If there is a balance remaining after attributing the distribution to Categories (a), (aa) and (b) (see IFM28025), the next part of the distribution is out of income of the property rental business (PRB). This includes the remaining PRB income of the relevant accounting period that is not covered by Category (a) and (aa) as well as any amounts of PRB income from previous years that have not already been allocated as distributions from Category (c). For information about the other Categories, see IFM28010.

For a Group REIT, the amount attributable to Category (c) is based on the measure of income that, across the various members of the group, has been exempted from tax as a consequence of the group being a UK-REIT. In attributing the distributable reserves of the principal company therefore it is not by reference to the nature of the profits as they arise to that company (which will often be as dividends paid up from subsidiaries that carry on property rental business), but by reference to the amount of the various kinds of profit that arise to all the members of the group.

The attribution of the distribution to category (c) may be restricted by the total amount of property rental business reserves available. It is not possible to attribute distributions in excess of the reserve available in category (c).