F1PART 4APROPERTY AIFS

Annotations:

CHAPTER 5THE TREATMENT OF PARTICIPANTS IN PROPERTY AIFS

Treatment of distributions: liability to tax of participants

PAIF distributions (interest): liability to tax of participants69Z19

F21

A PAIF distribution (interest) received by a participant in an open-ended investment company to which this Part applies shall be treated—

a

in the case of a participant within the charge to corporation tax, as if it were interest arising from a loan relationship; and

b

in the case of a participant within the charge to income tax, as if it were a payment of yearly interest falling within Chapter 2 of Part 4 of ITTOIA 2005.

2

Sections 231 of ICTA and 397 of ITTOIA 2005 (tax credits in respect of qualifying distributions) shall not apply to PAIF distributions (interest).