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

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