IFM29030 - Real Estate Investment Trust : Miscellaneous: indirect ownership of property: summary

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 / income

Group 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 count

Group 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.