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.