enables a group of companies which carries on property rental business and which meets requirements specified in Chapter 2 to opt to benefit from exemptions from corporation tax on profits and gains in accordance with Chapter 3, and

imposes liabilities to tax on members of the group and the recipients of distributions made by the principal company of the group.

Chapter 4 deals with some of the consequences of becoming, or becoming a member of, a UK REIT,

Chapters 5, 6 and 7 contain provision relating to (respectively) assets of, distributions made by, and gains arising to a UK REIT,

Chapter 8 contains provision about failure to meet requirements specified in Chapter 2,

Chapter 9 contains provision about ceasing to be, or to be a member of, a UK REIT,

Chapter 10 provides for the application of this Part in relation to property rental business carried on by way of a joint venture, and

Chapter 11 contains miscellaneous provision and definitions.

a group UK REIT (see section 523(5)), or

a company UK REIT (see section 524(5)).

UK property business (within the meaning given by section 205 of CTA 2009), and

overseas property business (within the meaning given by section 206 of that Act).

section 598(3) (which provides that certain lettings of property by a joint venture company or a member of a joint venture group are not property rental business),

section 604 (which provides that business of a specified class is not property rental business), and

section 605 (which provides that business giving rise to income of a specified class is not property rental business).

a non-UK company which is a member of a group UK REIT has UK property rental business, and

the profits of that business would be chargeable to income tax under Chapter 3 of Part 3 of ITTOIA 2005.

are to be treated for the purposes of this Part as if they were (subject to the application of this Part) chargeable to corporation tax, and

are not to be charged to income tax.

UK resident, and

not resident in another place in accordance with the law of that place relating to taxation.

it is a UK company, and

section 236 of FISMA 2000 (open-ended investment companies) does not apply to it.

it is a UK company, and

section 236 of FISMA 2000 (open-ended investment companies) does not apply to it.

must be given in writing to an officer of Revenue and Customs,

must be given before the date specified in the notice,

must be accompanied by a statement by the company giving the notice that each of F1conditions A, B, C, E and F in section 528 (conditions for company) is reasonably expected to be met in relation to the company throughout accounting period 1, and

must contain such other information, and be accompanied by such other documents, as may be prescribed by regulations made by the Commissioners for Her Majesty's Revenue and Customs.

does not expect to meet condition C in section 528 on the first day of accounting period 1, but

reasonably expects to meet that condition throughout the rest of accounting period 1.

subsection (1)(c) does not apply, but

the notice must be accompanied by a statement by the company containing the assertions specified in subsection (4).

that conditions A, B, F2... E and F in section 528 are reasonably expected to be met in relation to the company throughout accounting period 1, and

that condition C in that section is reasonably expected to be met in relation to the company for at least a part of the first day of accounting period 1, and throughout the remainder of the period.

each of the conditions in section 528 (conditions for company) must be met in relation to the principal company throughout the accounting period,

the condition in section 528A (further condition relating to shares) must be met in relation to the period F5(but see subsection (3A)),

the group must throughout the period have property rental business in relation to which conditions A and B in section 529 are met F6or in relation to which condition C is met (whether or not the group also has other business),

the condition in section 530 (distribution of profits) must be met in relation to the period,

conditions A and B in section 531 (balance of business) must be met in relation to the period, and

the principal company must prepare for the period, and submit to an officer of Revenue and Customs, financial statements under section 532.

each of the conditions in section 528 (conditions for company) must be met in relation to the company throughout the accounting period,

the condition in section 528A (further condition relating to shares) must be met in relation to the period, F8(but see subsection (3A))

the company must throughout the period have property rental business in relation to which conditions A and B in section 529 are met F9or in relation to which condition C is met (whether or not the company also has other business),

the condition in section 530 (distribution of profits) must be met in relation to the period, and

conditions A and B in section 531 (balance of business) must be met in relation to the period.

the shares forming the company's ordinary share capital are F13admitted to trading on a recognised stock exchange F14, or

at least 70% of the shares forming the company’s ordinary share capital are owned by one or more institutional investors (see sections 528ZA and 528ZB).

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

a person acting on behalf of an authorised contractual scheme (within the meaning given by section 237(3) of FISMA 2000) which is a co-ownership scheme (within the meaning given by section 235A of that Act) that meets the genuine diversity of ownership condition or the non-close condition;

a person acting on behalf of a limited partnership which is a collective investment scheme (as defined in section 235 of FISMA 2000) F26that meets the genuine diversity of ownership condition or the non-close condition;

the trustee or manager of a pension scheme (as defined in section 150(1) of FA 2004);

a charity;

a person who cannot be liable for corporation tax or income tax (as relevant) on the ground of sovereign immunity.

a UK REIT;

a person who is resident in a territory outside the United Kingdom in accordance with the law of that territory relating to taxation and is F29... the equivalent of a UK REIT

paragraph (a)(ii) were omitted, and

in paragraph (b), in the words before sub-paragraph (i), “or (ii)” were omitted.

company if it is prevented from being a close company only by section 444 or 447(1)(a) F34, and

ignore paragraph (a) of section 442 (non-UK resident companies deemed not to be close).

a person is a “direct participator” if the person is a participator for the purposes of Part 10 of CTA 2010 (see section 454), and

a person is an “indirect” participator in a company if the person has a share or interest in the capital or income of the company through another body corporate or other bodies corporate.

reference to having a share or interest in the capital or income of a company through a body corporate is to be read in accordance with sub-paragraphs (9) and (10) of paragraph 46 of Schedule 5AAA to TCGA 1992 (meaning of direct or indirect participator), and

a person is regarded for the purposes of those sub-paragraphs, and for the purposes of subsection (5B)(b) of this section, as having a share or interest in the capital or income of a company if the person would be a participator in the company as a result of section 454(2) of CTA 2010.

the rights and powers of a person (“A”) are not to be attributed to another person (“P”) merely because A is a partner of P for the purposes of any attribution under section 451(4) (rights of a person's associates to be attributed to the person etc in determining “control”), and

there is no more than one class of ordinary share issued by the company.

“restricted preference share” means a share which is a restricted preference share (within the meaning of section 160) or would be but for the fact that it carries a right of conversion into shares or securities in the company, and

a share is “non-voting” if it carries no right to vote at a general meeting of the company or if it carries a right to vote which is contingent on the non-payment of a dividend and which has not become exercisable.

the loan creditor is not entitled to an amount by way of interest which depends to any extent on the results of all or part of the company's business or on the value of any of the company's assets,

the loan creditor is not entitled to an amount by way of interest which exceeds a reasonable commercial return on the consideration lent, and

the loan creditor is entitled on repayment to an amount which either does not exceed the consideration lent or is reasonably comparable with the amount generally repayable (in respect of an equal amount of consideration) under the terms of issue of securities listed on a recognised stock exchange.

for the interest to be reduced in the event of the results improving, or

for the interest to be increased in the event of the results deteriorating.

directly,

indirectly, or

partly directly and partly indirectly.

an exempt unauthorised unit trust,

anything which is included in references to a body corporate for the purposes of paragraph 46 of Schedule 5AAA to the TCGA 1992 (UK property rich collective investment vehicles etc) (see sub-paragraph (12) of that paragraph), and

an authorised contractual scheme which is a co-ownership scheme,

the conditions in regulation 75(2), (3) and (4)(a) of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), or

the condition in regulation 75(5) of those Regulations (assuming for this purpose that regulation 75(4)(b) is omitted),

multi-vehicle arrangements, and

a collective investment scheme which is not an offshore fund.

the limited capacity of the scheme to receive investments is fixed by the documents of the F46scheme (or otherwise), and

a pre-determined number of specific persons, or specific groups of connected persons, make investments in the F46scheme that collectively exhaust all, or substantially all, of that capacity.

throughout the accounting period, the shares forming the principal company's ordinary share capital meet the requirement of section 1137(2)(b) (definition of “listed” in relation to shares), or

during the accounting period, shares forming part of the principal company's ordinary share capital are traded on a recognised stock exchange.

throughout the accounting period, the shares forming the company's ordinary share capital meet the requirement of section 1137(2)(b) (definition of “listed” in relation to shares), or

during the accounting period, shares forming part of the company's ordinary share capital are traded on a recognised stock exchange.

at the end of the relevant period, the shares forming the principal company's ordinary share capital meet the requirement of section 1137(2)(b) (definition of “listed” in relation to shares), or

during the relevant period, shares forming part of the principal company's ordinary share capital are traded on a recognised stock exchange.

at the end of the relevant period, the shares forming the company's ordinary share capital meet the requirement of section 1137(2)(b) (definition of “listed” in relation to shares), or

during the relevant period, shares forming part of the company's ordinary share capital are traded on a recognised stock exchange.

the value of which is equal to, or F53in excess of, £20 million F54..., and

which is designed, fitted or equipped for the purpose of being rented, and is rented or available for rent, as a commercial unit.

entry, and

when the property was acquired.

a reference to a property “involved” in a business is a reference to an estate, interest, or right by the exploitation of which the business is conducted,

a property is a single property if it is designed, fitted or equipped for the purpose of being rented, and it is rented or available for rent, as a commercial or residential unit (separate from any other commercial or residential unit),

assets must be valued in accordance with international accounting standards,

where international accounting standards offer a choice of valuation between cost basis and fair value, fair value must be used, and

no account is to be taken of liabilities secured against or otherwise relating to assets (whether generally or specifically).

so much of the group's UK profits arising in the period as are UK REIT investment profits (see section 549A), and

at least 90% of the rest of the group's UK profits arising in the period,

the condition applies to profits of the property rental business attributable to a member of the group, and

compliance with the condition by the member would (if the condition applied to it) be unlawful as a result of a relevant enactment.

so much of the profits of the company's property rental business arising in the period as are UK REIT investment profits (see section 549A), and

at least 90% of the rest of the profits of the company's property rental business arising in the period,

a dividend in cash, and

share capital issued in lieu of a cash dividend.

(apart from that subsection) there would be a a failure to meet the condition in this section in relation to an accounting period, and

that failure would arise solely by reason of the operation, by virtue of section 599A(2), of section 412(2) of ITTOIA 2005 (substitution of market value) in relation to any distributions within subsection (6A)(b).

an enactment (including Northern Ireland legislation and an Act of the Scottish Parliament), or

an enactment of a jurisdiction outside the United Kingdom if the enactment is prescribed, or is of a kind prescribed, for the purposes of this paragraph in regulations made by the Commissioners for Her Majesty's Revenue and Customs.

the principal company of the group delivered with its tax return for the period the financial statement under section 532(2)(b) showing the amount of the UK profits of the group arising in the period, and

as at the relevant date, those profits have been increased from the amount originally shown in the statement.

the company delivered its tax return for the period showing the amount of the profits of its property rental business arising in the period as calculated in accordance with section 599, and

as at the relevant date, those profits have been increased from the amount originally shown in the return.

the profits of property rental business of members of the group F67..., and

the profits of residual business of members of the group F68...

the reference in subsection (2)(a) to the profits of property rental business of members of the group are to those profits as shown in the financial statement under section 532(2)(a), and

the reference in subsection (2)(b) to the profits of residual business of members of the group are to those profits as shown in the financial statement under section 532(2)(c).

profits of property rental business of the company, and

profits of residual business of the company.

realised and unrealised gains and losses on the disposal of property,

changes in the fair value of hedging derivative contracts (within the meaning given by section 599(4)), F72...

items which are outside the ordinary course of the group's or, as the case may be, the company's business (irrespective of their treatment in the group's or company's accounts), having regard to that group's or company's past transactionsF73, and

the value of the assets relating to property rental business, and

the value of the assets relating to residual business so far as consisting of cash F76or relevant UK REIT shares ,

the amount shown in the financial statement under section 532(2)(a) as the amount of the assets of members of the group is to be treated as the amount of the assets relating to property rental business, and

the amount shown in the financial statement under section 532(2)(c) as the amount of the assets of members of the group is to be treated as the amount of the assets relating to residual business F78(and the amount of the group's cash F79and relevant UK REIT shares is to be determined accordingly) .

an asset relates to property rental business if it would be shown as an asset if separate accounts were prepared for the property rental business,

assets must be valued in accordance with international accounting standards,

where international accounting standards offer a choice of valuation between cost basis and fair value, fair value must be used, and

no account is to be taken of liabilities secured against or otherwise relating to assets (whether generally or specifically).

assets held solely in connection with the items mentioned in subsection (4)(b) and (c), and

assets of residual business of members of the group or of the company held solely as a result of compliance with planning obligations entered into as mentioned in subsection (4)(d).

money held on deposit (whether or not in sterling),

stocks or bonds of any description included in Part 1 of Schedule 11 to FA 1942 (gilts), or

money held in any other way, or any investment of any other form, specified in regulations made by the Commissioners for Her Majesty's Revenue and Customs.

in the case of a group UK REIT, shares held by a member of the group in the principal company of another group UK REIT or in a company UK REIT, and

in the case of a company UK REIT, shares held by the company in the principal company of a group UK REIT or in another company UK REIT.

a financial statement for the group's property rental business for the accounting period,

a financial statement for the group's property rental business in the United Kingdom for the period, and

a financial statement for the group's residual business for the period.

property rental business of UK members of the group, and

UK property rental business of other members.

profits (calculated in accordance with international accounting standards),

expenses (calculated in accordance with international accounting standards),

profits before tax excluding gains or losses on property (whether realised or not) calculated in accordance with international accounting standards, F84...

the items specified in section 531(4)(b) to (d), and

in connection with the items mentioned in section 531(4)(b) and (c), or

as a result of compliance with planning obligations entered into as mentioned in section 531(4)(d).

the profits of property rental business of the group, and

the profits of residual business of the group.

the references to profits in subsection (1B) are to profits determined in the same way as profits are determined in accordance with section 531(4);

any expenses relating to both property rental business and residual business are to be apportioned on a just and reasonable basis.

the value of the assets relating to property rental business, and

the value of the assets relating to residual business so far as consisting of cash or relevant UK REIT shares,

assets held solely in connection with the items mentioned in section 531(4)(b) and (c), and

assets held solely as a result of compliance with planning obligations entered into as mentioned in section 531(4)(d).

make further provision relating to the content of a financial statement under section 532,

prescribe the form of a financial statement, and

specify a time before which a financial statement must be submitted to an officer of Revenue and Customs.

permit or require apportionment or otherwise prescribe or refer to accounting practice;

provide for the inclusion or exclusion of specified profits, expenses, gains, losses, assets and liabilities;

make provision about the treatment of an interest in a business held by a member.

in the case of a group UK REIT, to the group and to each company which is a member of the group, and

to a company UK REIT.

business of the pre-entry group or pre-entry company,

residual business of the group or company, and

business of the post-cessation group or post-cessation company.

the pre-entry group or pre-entry company,

the group or company so far as it carries on residual business, and

the post-cessation group or post-cessation company.

a loss made in property rental business may not be set off against profits of residual business,

a loss made in residual business may not be set off against profits of property rental business,

a loss made in business carried on before entry may not be set off against profits of property rental business,

a loss made in property rental business may not be set off against profits of business carried on after cessation (in respect of business of any kind), and

receipts accruing after entry but relating to business carried on before entry are not treated as receipts of property rental business.

if less, the amount equal to 20% of PP.

in the case of a group UK REIT, of the principal company of the group, and

in the case of a company UK REIT, of the company.

the company was in severe financial difficulties at a time in the accounting period,

the result of the calculation in subsection (2) is less than 1.25 in respect of the accounting period because of circumstances that arose unexpectedly, and

in those circumstances the company could not reasonably have taken action to avoid the result being less than 1.25.

in the case of a group UK REIT, the sum of the profits of property rental business of members of the group that arise in the period, as shown in the financial statement under section 532(2)(b), and

in the case of a company UK REIT, the amount of the profits of the company's property rental business (calculated in accordance with section 599) that arise in the period.

capital allowances,

losses from a previous accounting period, and

amounts taken into account as a result of section 599(3).

in the case of a group UK REIT, the amount of the financing costs incurred in respect of F103the group's property rental business in the United Kingdom, excluding financing costs owed by one member of the group to another, as shown in the financial statement under section 532(2)(a), and

in the case of a company UK REIT, the amount of the financing costs incurred in the period in respect of the company's property rental business.

property rental business of UK members of the group, and

UK property rental business of other members.

interest payable on borrowing,

amortisation of discounts relating to borrowing,

amortisation of premiums relating to borrowing,

the financing expense implicit in payments made under finance leases, F107...

alternative finance return (as defined in sections 511 to 513 of CTA 2009),

amortisation of discounts and premiums relating to a derivative contract or other arrangement within paragraph (f).

in relation to any person, a lease that, in accordance with generally accepted accounting practice, falls (or would fall) to be treated in the accounts of that person as a finance lease or loan, or

in relation to a lessee under a right-of-use lease, a lease that would fall to be treated in the accounts of the lessee as a finance lease if the lessee were required under generally accepted accounting practice to determine whether the lease falls to be so treated.

an assessment;

the cancellation of a right of repayment;

a requirement to return a repayment already made;

the calculation or recalculation of profits or gains, or liability to tax, on a basis specified in the notice.

to create or inflate or apply a loss, deduction or expense (whether or not made or incurred by the company), or

to have another effect of a kind specified for the purposes of this subsection by regulations made by the Treasury.

quash the notice under section 545(1),

affirm the notice, or

vary the notice.

company UK REIT or a member of a group UK REIT disposes of an asset used wholly and exclusively for the purposes of property rental business, and

the company UK REIT or any member of the group UK REIT holds the proceeds in cash.

are to be ignored for the purposes of section 599 (calculation of profits), and

are to be treated for all tax purposes as arising from a loan relationship entered into in connection with residual business.

held on deposit (whether or not in sterling),

invested in stocks or bonds of any of the descriptions included in Part 1 of Schedule 11 to FA 1942 (gilts), or

held or invested in such other form as the Commissioners for Her Majesty's Revenue and Customs may specify for the purposes of this section in regulations.

partly for the purposes of property rental business of the company, and

partly for the purposes of residual business of the company,

profits or gains (or both) of UK members of the group, or

profits or gains (or both) of UK property rental business of non-UK members of the group.

subsection (1)(a) is to be read as referring to the principal company of the post-cessation group, or (as the case may be)

subsection (1)(b) is to be read as referring to the post-cessation company.

is a person who is charged to tax under Part 3 of CTA 2009 (trading income) in respect of distributions made by companies that are received in the course of a trade not consisting of insurance business,

is a dealer in securities who is charged to income tax under Part 2 of ITTOIA 2005 (trading income) in respect of distributions made by companies,

in the case of a company UK REIT, a distribution from the company in respect of profits or gains (or both) of its property rental business.

any other UK property business (within the meaning given by section 205 of CTA 2009) carried on by the shareholder,

any other UK property business (within the meaning given by section 264 of ITTOIA 2005) carried on by the shareholder,

any overseas property business (within the meaning given by section 206 of CTA 2009) carried on by the shareholder, and

any overseas property business (within the meaning given by section 265 of ITTOIA 2005) carried on by the shareholder.

it is a distribution in respect of profits or gains (or both) of property rental business of the company.

distributions made by the principal company of a group UK REIT, and

distributions made by a company UK REIT.

first, to distributions in satisfaction of the requirement of section 530(1)(a) or 530(4)(a) (as the case may be),

second, to distributions in satisfaction of the requirement of section 530(1)(b) or 530(4)(b) (as the case may be),

F125third , so far as the company determines, to distribution of amounts which derive from activities of a kind in respect of which corporation tax is chargeable in relation to income,

F126fourth , to distribution of profits of property rental business (calculated in accordance with section 599),

F127fifth , to distribution of relevant non-chargeable gains, and

F128sixth , to other distributions.

in the case of a group, gains accruing to property rental business of a member of the group, and

in the case of a company, gains accruing to property rental business of the company,

a distribution is made to or in respect of a holder of excessive rights F131that is not an excluded holder (both as defined by section 553), and

the distributor has not taken reasonable steps to prevent a distribution to or in respect of such a person from being made.

in the case of a group UK REIT, the principal company of the group, and

in the case of a company UK REIT, the company.

as arising in the accounting period in which the distribution was made, and

as profits of residual business of the distributor.

condition A, and

either condition B or C.

is beneficially entitled (directly or indirectly) to at least 10% of the F137distributions paid by the distributor,

is beneficially entitled (directly or indirectly) to at least 10% of the distributor's share capital, or

controls (directly or indirectly) at least 10% of the voting rights in the distributor.

those arrangements have effect by virtue of an Order in Council under section 2 of TIOPA 2010.

in accordance with double taxation arrangements (within the meaning of section 2(4) of TIOPA 2010), the holder is taxed at a particular rate, or not taxed at all, on distributions from a UK REIT, unless the sole reason for that treatment is the size of the holder’s interest in the UK REIT, or

the holder is a person to whom a payment of a distribution must be made without deduction of income tax in accordance with regulation 7 of the Real Estate Investment Trusts (Assessment and Recovery of Tax) Regulations 2006 (S.I. 2006/2867) (gross payment of distributions).

the principal company of a group UK REIT, or

a company UK REIT,

provision that a charge does not arise, or is reduced, if the company takes or does not take action of a specified kind;

a requirement for the company to provide the Commissioners for Her Majesty's Revenue and Customs with specified information relating to the distribution and the persons to or in respect of whom it is made.

an asset has been used wholly and exclusively for the purposes of property rental business of a company which is, or is a member of, a UK REIT, and

the asset begins to be used (otherwise than by being disposed of in the course of trade) wholly and exclusively for the purposes of residual business of the company.

disposed of by the company so far as it carries on property rental business, and

immediately reacquired by the company so far as it carries on residual business.

subsection (3) does not apply, and

anything done by or to the company so far as it carries on property rental business before the deemed sale and reacquisition is to be treated after the deemed sale and reacquisition as having been done by or to the company so far as it carries on residual business.

an asset has been used wholly and exclusively for the purposes of property rental business of a company which is, or is a member of, a UK REIT, F140...

the asset is disposed of in the course of trade for the purposes of residual business of the companyF141, and

if the company is a member of a UK REIT, the disposal is not to another member of the UK REIT.

the deemed sale and reacquisition under section 536(2) is to be ignored, and

the asset is to be treated as having been disposed of in the course of the company's residual business.

a property acquired by a company which is, or is a member of, a UK REIT has been developed since acquisition,

the cost of the development exceeds 30% of the F142... value of the property F143... ,

the company disposes of the property within the period of 3 years beginning with the completion of the development F144, and

if the company is a member of a UK REIT, the disposal is not to another member of the UK REIT.

on entry;

when the property was acquired;

the beginning of the accounting period in which the development commenced.

one or more properties acquired (directly or indirectly) by a relevant UK property rich company have been developed since acquisition,

the cost of the development exceeds 30% of the F147... value of the property F148...,

C disposes of any of its rights or interests in the relevant UK property rich company,

the disposal is made within the period of 3 years beginning with the completion of the development, and

if C is a member of a UK REIT, the disposal is not to another member of the UK REIT.

on entry;

when the property was acquired;

the beginning of the accounting period in which the development commenced.

a company is a “relevant UK property rich company” if, as a result of section 535A, any part of a gain accruing to C on a disposal of a right or interest in the company would not be a chargeable gain, and

a relevant UK property rich company acquires property “indirectly” if property is acquired by someone other than the relevant UK property rich company and the property is taken into account in determining the value of the assets of the relevant UK property rich company.

an asset has been used wholly and exclusively for the purposes of residual business of a company which is, or is a member of, a UK REIT, and

the asset begins to be used wholly and exclusively for the purposes of the company so far as it carries on property rental business.

disposed of by the company so far as it carries on residual business, and

immediately reacquired by the company so far as it carries on property rental business.

subsection (3) does not apply, and

anything done by or to the company so far as it carries on residual business before the deemed sale and reacquisition is to be treated after the deemed sale and reacquisition as having been done by or to the company so far as it carries on property rental business.

the company (“C”) disposes of an asset involved in its property rental business to a 75% subsidiary (“S”) of C,

C (so far as it carries on residual business) disposes of its interest in S to another company (“P”),

on the date when P acquires the interest in S, P gives a notice under section 523 specifying a date that falls within the post-disposal period, and

the group of which S is a member becomes a group UK REIT from the specified date.

in relation to the asset disposed of by C, or

in relation to business conducted by the exploitation of that asset.

in a case within subsection (3)(a), the principal company of Group 2 gives a notice under section 523 no later than the date on which the exiting company ceases to be a member of Group 1, and

in a case within subsection (3)(b), the exiting company gives a notice under section 524 no later than the date on which it ceases to be a member of Group 1.

this section does not apply, and

the exiting company is to be treated as having ceased to be a member of a group UK REIT (or a company UK REIT) on the date on which it ceased to be a member of Group 1.

by a notice given by the principal company of the group or (as the case may be) by the company (see section 571), or

in the cases set out in sections 573 to 577, by a notice given by an officer of Revenue of Customs (see section 572).

the principal company of a group UK REIT, or

a company UK REIT,

to the principal company of a group UK REIT, or

to a company UK REIT,

the group or company (as the case may be) is to be taken to have ceased to be a UK REIT at the end of the accounting period before the accounting period during which the event occurs (or the last event occurs) which caused the officer to give the notice, and

the company to which the notice is given may appeal.

at any time during the first 3-year period, condition D in section 528 is not met, and

as at that time, subsection (2) has applied to a member of the group or the company (as the case may be) for a period exceeding 3 years or for a number of periods which in total exceed 3 years.

the company is, or is a member of, a UK REIT,

condition D in section 528 is not met in relation to the UK REIT, and

the first 3-year period in relation to the UK REIT has not ended.

the principal company of a group UK REIT becoming a member of another group UK REIT, or

a company UK REIT becoming a member of a group UK REIT.

a company ceases to carry on a business (“the transferred business”) which it carried on at a time (“the relevant time”) when subsection (2) applied to the company, and

another company (“company X”) begins to carry on the transferred business.

company X, and

if company X subsequently ceases to carry on the transferred business (or any part of it), any other companies which from time to time carry on the transferred business (or any part of it).

the first day of accounting period 1, or

such later day as may be specified by the officer of Revenue and Customs in the notice.

the condition in section 528A (further condition relating to shares) would not be met in relation to an accounting period (“the relevant accounting period”) but for section 528B, and

subsection (2) applies to a company which is a member of the group at any time during the relevant accounting period.

the condition in section 528A (further condition relating to shares) would not be met in relation to an accounting period (“the relevant accounting period”) but for section 528B, and

the company has benefited from the relaxation of the condition in section 528A in relation to 3 or more accounting periods (apart from the relevant accounting period).

it is a member of a group UK REIT at any time during an accounting period in relation to which the condition in section 528A would not be met but for section 528B, or

at any time it is a company UK REIT and the condition in section 528A would not be met in relation to an accounting period but for section 528B,

the principal company of a group UK REIT becoming a member of another group UK REIT, or

a company UK REIT becoming a member of a group UK REIT.

a company ceases to carry on a business (“the transferred business”) which it carried on at any time during an accounting period in relation to which the company benefits from the relaxation of the condition in section 528A, and

another company (“company X”) begins to carry on the transferred business.

company X, and

if company X subsequently ceases to carry on the transferred business (or any part of it), any other companies which from time to time carry on the transferred business (or any part of it).

the first day of accounting period 1, or

such later day as may be specified by the officer of Revenue and Customs in the notice.

a breach of a condition in section 529, 530 or 531, or

an attempt by a member of the group or (as the case may be) by the company to obtain a tax advantage,

the case is one relating to a breach of condition B in section 531 (balance of business: assets) in relation to accounting period 1, and

that condition is not met at the beginning of the next accounting period.

more than twice in relation to condition A in section 529, F195...

more than twice in relation to condition B in that section F196, or

more than twice in relation to Condition C in that section.

more than one accounting period, but

not more than two accounting periods,

the provisions referred to in subsection (4) are—

• F198section 562A(6) ,

• section 563(2), and

• section 568(1) and (2), and

“the relevant 10-year period” is the period of 10 years beginning with the day on which the first of the conditions to be breached was first breached.

a breach of condition C F199... in section 528 in respect of which section 525(2) to (4) F199... applies,

a breach of any of conditions F200C, E and F in section 528 in respect of which section 558(3) or 559(6) applies,

a breach of condition A in section 531 in accounting period 1, and

a breach of condition B in section 531 at the beginning of that period.

a group or company ceases to be a UK REIT, or

a company ceases to be a member of a group UK REIT.

sold immediately before cessation by the company so far as it carries on property rental business, and

reacquired immediately after cessation by the post-cessation company.

an accounting period of the company so far as it carries on residual business ends on cessation, and

a new accounting period of the company begins.

a member of a group UK REIT becomes a member of another group UK REIT, or

a company UK REIT becomes a member of a group UK REIT.

does not give rise to allowances or charges, and

does not enable an election to be made under section 198 or 199 of CAA 2001 (apportionment).

in the case of a group, a member of the group, or

otherwise, the company,

any deemed disposal under section 536(2) that resulted in a gain,

any deemed disposal under section 555(2), or

any deemed disposal under section 579(4).

a company ceases to be a member of a group UK REIT,

during the post-cessation period the company disposes of an asset that was involved in its property rental business.

a group or a company ceases to be a UK REIT as a result of section 572 or 578, and

the group or company has been a UK REIT for a continuous period immediately before cessation of less than 10 years.

that a provision of this Part applies in relation to the group or company with a specified modification, or

that a provision of an enactment relating to corporation tax applies, does not apply or applies with modifications in relation to the group or company.

alter the time at which the group or company is to be taken to cease to be a UK REIT in accordance with section 572 or 578;

disapply or alter the effect of section 534(1) or (2)F202, 535(1) or 535A.

in the case of a group in relation to which a direction is given, by the principal company of the group,

in the case of a company in relation to which a direction is given, by the company.

quash the direction,

affirm the direction, or

vary the direction.

by a joint venture company (as defined by section 584), or

by one or more members of a joint venture group (as defined by that section).

specific modifications and other provision relevant to the application of this Part (see sections 591 to 594),

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

provision about the interpretation of this Chapter (see section 598).