Commentary

D7.1156 The REIT regime and non-UK resident group companies

Corporate tax
Corporate tax | Commentary

D7.1156 The REIT regime and non-UK resident group companies

Corporate tax | Commentary

D7.1156 The REIT regime and non-UK resident group companies

In accordance with the provisions described in D7.1152, non-UK resident companies are included within the group UK REIT.

UK business of non-resident companies

Single company UK REITs have to be UK resident1. As such, the property rental business for single company REITs comprises the UK and overseas property business of the company (see D7.1102).

For group UK REITs, property rental business includes the UK and overseas property business of UK resident group companies and also, as described in D7.1102, the UK and overseas property business of non-UK group companies (provided it would be property rental business if carried on by a UK company)2. However, for the purposes of the exemption from tax and the distribution requirement, only the UK property rental business of non-UK resident companies is included, together with the UK and overseas property rental business of UK resident companies (defined in total as the group's property rental business in the UK)3.

Non-UK resident

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