The treatment of groups of companies to which the REIT regime applies (hereafter referred to as group UK REITs) is broadly the same as single company UK REITs, but there are some particular differences as discussed below in relation to:
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•ÌýÌýÌýÌý the qualifying conditions and joining/leaving a group REIT
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•ÌýÌýÌýÌý inter-company charges, in relation to loans, goods and services etc
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•ÌýÌýÌýÌý intra-group transactions
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•ÌýÌýÌýÌý the definition of a group REIT and the interaction with other general group taxation rules
Qualifying conditions and joining/leaving a group REIT
Profit : financing-cost ratio
The formula by which the profit : financing-cost ratio (see D7.1104) is determined for group UK REITs differs from that for single company UK REITs.
For group UK REITs, the formula compares the sum of property rental profits, before capital allowances and financing costs, of each company in the group (as calculated for tax purposes under CTA 2010, s 599 (see D7.1115A) and set out in the financial statements at CTA 2010, s 532(2)(b)
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Web page updated on 17 Mar 2025 13:36