Part 12Real Estate Investment Trusts

Chapter 6Distributions

Attribution of distributions

550Attribution of distributions

1

Subsection (2) applies to—

a

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

b

distributions made by a company UK REIT.

2

The distributions are to be attributed—

a

first, to F1distributions in satisfaction of the condition in section 530 (distribution of profits),

b

second, 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,

c

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

d

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

e

fifth, to other distributions.

3

In subsection (2)(d) “relevant non-chargeable gains” means—

a

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

b

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

which as a result of section 535 are not chargeable gains.