Commentary

D8.141 Tax implications

Corporate tax
Corporate tax | Commentary

D8.141 Tax implications

Corporate tax | Commentary

D8.141 Tax implications

Entry to the regime

Where the qualifying conditions (D8.142) are met, such that a company can enter the regime, a new distribution period of the authorised investment fund commences1.

Implications during regime

For the purposes of corporation tax, income arising to a TEF will consist of2:

  1.  

    (a)     distribution income (treated as an exempt distribution3) which consists of:

    1.  

      (1)     dividend income which includes UK dividends and overseas dividends;

    2.  

      (2)     property investment income in relation to shares held in a UK REIT or in a property authorised investment fund;

    3.  

      (3)     property business income; and

  2.  

    (b)     other, non-dividend income.

Allocation of income made by TEFs

Allocations of income (distributions) by a TEF will either be as TEF distributions (dividends) or as TEF distributions (non-dividend)4. In most cases, investors will receive both types of distribution for each distribution period and be taxed accordingly. TEF distributions (dividends) will consist of income attributable to (a) above and TEF distributions (non-dividend) will consist of income attributable to (b) above. Note that for the purpose of the

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