Once a company enters the REIT regime there is effectively a 'ring fence' around the tax exempt property rental business carried on by a company. The ring fence is there to isolate the profits, losses and gains of the property rental business from those arising from other activities carried on by the company.
Accordingly, it is provided that, for the purposes of corporation tax, the business of the company UK REIT is treated as a separate business distinct from1:
- Ìý
•ÌýÌýÌýÌý any business carried on by the pre-entry company
- Ìý
•ÌýÌýÌýÌý any residual business of the company, and
- Ìý
•ÌýÌýÌýÌý any business carried on by the post-cessation company
The tax-exempt property rental business is however one business and as such losses arising from
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