UK REITs—groups and joint ventures
Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP
UK REITs—groups and joint ventures

The following Tax practice note produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP provides comprehensive and up to date legal information covering:

  • UK REITs—groups and joint ventures
  • UK group REITs
  • What counts as a group for the purposes of the UK REIT regime?
  • Conditions for UK group REITs
  • Principal company conditions
  • Non-UK group members
  • UK group REIT treatment
  • Indirect ownership of property
  • Partnerships
  • Offshore unit trusts
  • More...

FORTHCOMING CHANGE: As part of review of the UK funds regime and in particular, a consultation on the tax treatment of asset holding companies, the government consulted until 23 February 2021 on changes to the real estate investment trust (REIT) regime including the:

  1. listing requirement

  2. institutional investors and close company requirement

  3. holders of excessive rights rule, and

  4. balance of business test

The government also consulted until 20 April 2021 on the UK funds regime more generally and sought views on REITs and

  1. the interest cover test and the corporate interest restriction

  2. the three-year development rule

  3. the three property rule, and

  4. the overseas property rules

See: Taxation of asset holding companies in alternative fund structures (second stage consultation), Review of the UK funds regime: a call for input and News Analysis: Promoting UK funds—potential reform of the UK REIT regime.

The UK real estate investment trust (REIT or UK REIT) regime applies both to sole companies and to groups of companies. In practice, however, the great majority of UK REITs are formed of groups of companies.

This Practice Note considers:

  1. UK group REITs—including, in particular, the specific requirements and tests for a group of companies to qualify as a UK group REIT and the consequent tax treatment of the UK group REIT

  2. indirect ownership of property by UK group REITs—including, in particular, the structures through which a UK

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