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:

2. 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

3.  

   (b)     other, non-dividend income.

Allocation of income made by TEFs

Allocations of income (distributions) by a TEF will either be as TEF