Amendment to the Corporation Tax Act 20102.
(1)
The Corporation Tax Act 2010 is amended as follows.
(2)
In section 528(4A) (conditions for company, meaning of “institutional investor”)3, at the end insert—
“(i)
a UK REIT;
(j)
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, under the law of that territory, the equivalent of a UK REIT”.
(3)
In section 544(5) (property financing costs)4—
(a)
at the end of paragraph (d) omit “and”, and
(b)
after paragraph (e) insert—
“(f)
periodic payments or receipts so far as they—
(i)
are from any derivative contract or other arrangement entered into as a hedge of risk in connection with borrowing, and
(ii)
are attributable to the hedge, and
(g)
amortisation of discounts and premiums relating to a derivative contract or other arrangement within paragraph (f)”.