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Investment Funds Manual
Publication Date: 2024
Publisher: Bloomsbury Professional
Copyright: 2024 Crown
Investment Funds Manual
Guidance on the tax rules affecting investment funds and fund managers.
Last update: 31st August 2024
Contents
- IFM01000: Introduction to Investment Funds Manual
- Close sectionIFM02000: Taxation of authorised investment funds
- Close sectionIFM02100: Taxation of authorised investment funds: introduction
- IFM02110: Authorised investment funds (AIFs): general
- IFM02120: Authorised investment funds (AIFs): authorised unit trusts
- IFM02130: Authorised investment funds (AIFs): open-ended investment companies
- IFM02140: Authorised investment funds (AIFs): structure, arrangement and tax status of funds: umbrella funds or companies
- Close sectionIFM02200: Authorised investment funds (AIFs): structure, arrangement and tax status of funds: umbrella funds or companies
- IFM02210: Authorised investment funds (AIFs): taxation of funds: taxation of funds: introduction
- IFM02220: Authorised investment funds (AIFs): distributions and unit classes
- IFM02222: Authorised investment funds (AIFs): taxation of funds: interest distributions
- IFM02224: Authorised investment funds (AIFs): taxation of funds: interest distributions - qualifying investments test
- IFM02230: Equalisation
- IFM02235: Authorised investment funds (AIFs): structure, arrangement and tax status of funds: manager's “box”
- IFM02240: Authorised investment funds (AIFs): taxation of funds: interest paid, loan relationships and derivative contracts
- IFM02250: Authorised investment funds (AIFs): Interests in non-reporting offshore funds
- IFM02260: Authorised investment funds (AIFs): taxation of funds: investment transactions
- IFM02265: Investment transactions - anti-avoidance
- IFM02270: Authorised investment funds (AIFs): taxation of funds: management expenses
- IFM02280: Authorised investment funds (AIFs): taxation of funds: capital allowances
- IFM02290: Authorised investment funds (AIFs): taxation of funds: groups and group relief claims
- Close sectionIFM02300: Taxation of authorised investment funds (AIFs): qualified investor schemes (QISs) and long-term asset funds (LTAFs)
- IFM02310: Authorised investment funds (AIFs): qualified investor schemes (QISs) and long-term asset funds (LTAFs): introduction
- IFM02320: Qualified investor schemes (QISs) and long-term asset funds (LTAFs): tax and the genuine diversity of ownership condition
- IFM02330: Authorised investment funds (AIFs): qualified investor schemes (QISs) and long-term asset funds (LTAFs): consequences of breaching the genuine diversity of ownership (GDO) condition
- IFM02340: Excess financing costs in a qualified investor scheme (QIS) which is a property authorised investment fund (PAIF)
- Close sectionIFM02400: Taxation of funds investing in non-reporting offshore funds (FINROF)
- IFM02410: Funds Investing in Non-Reporting Offshore Funds (FINROF): Introduction
- IFM02420: What is a Fund Investing in Non-Reporting Offshore Funds (FINROF)?
- IFM02430: Tax treatment of Funds Investing in Non-Reporting Offshore Funds (FINROF)
- IFM02440: Leaving the Funds Investing in Non-Reporting Offshore Funds (FINROF) regime
- IFM02500: Authorised investment funds (AIFs): Stamp duty and Stamp duty reserve tax (SDRT)
- IFM02600: Authorised investment funds (AIFs): VAT
- IFM02700: Authorised investment funds (AIFs): Double taxation treaties
- Close sectionIFM02100: Taxation of authorised investment funds: introduction
- Close sectionIFM03000: Investors in authorised investment funds (AIFs): contents
- Close sectionIFM03100: Investors in authorised investment funds (AIFs)
- IFM03200: Investors in authorised investment funds (AIFs) receiving trail commission
- Close sectionIFM03300: Tax treatment of investors in authorised investment funds (AIFs)
- IFM03310: Tax treatment of investors in authorised investment funds (AIFs): introduction
- IFM03320: Authorised investment funds (AIFs): taxation of investors within the charge to CT: dividend distributions
- IFM03322: Authorised investment funds (AIFs): taxation of investors within the charge to CT: interest distributions
- IFM03324: Authorised investment funds (AIFs): taxation of investors within the charge to CT: loan relationships
- IFM03326: Authorised investment funds (AIFs): taxation of investors within the charge to CT: qualifying investments test
- IFM03330: Authorised investment funds: taxation of investors within the charge to CT: financial traders and diversely owned AIFs: special rules
- IFM03335: Authorised investment funds (AIFs): taxation of investors within the charge to CT: financial traders and diversely owned AIFs: meaning of “financial trader”
- IFM03340: Authorised investment funds (AIFs): taxation of investors within the charge to CT: disposals of units
- IFM03350: Authorised investment funds (AIFs): taxation of investors within the charge to IT: distributions
- IFM03360: Authorised investment funds (AIFs): taxation of investors within the charge to IT: financial traders and diversely owned AIFs: special rules
- IFM03365: Authorised investment funds (AIFs): taxation of investors within the charge to IT: financial traders and diversely owned AIFs: meaning of “financial trader”
- IFM03370: Authorised investment funds (AIFs): taxation of investors within the charge to IT: disposals
- Close sectionIFM03400: Tax treatment of investors in qualified investor schemes (QISs) and long-term asset funds (LTAFs)
- IFM03410: Tax treatment of investors in qualified investor schemes (QISs) and long-term asset funds (LTAFs): Basic position
- IFM03420: Tax treatment of investors in qualified investor schemes (QISs) and long-term asset funds (LTAFs): consequences if the genuine diversity of ownership condition is breached
- Close sectionIFM04000: Property authorised investment funds (PAIFs)
- Close sectionIFM04100: Introduction and conditions of membership for the regime
- IFM04110: Introduction
- IFM04120: Overview of conditions
- IFM04130: The property investment business condition
- IFM04140: Foreign equivalents to ‘UK REITs’
- IFM04150: Intermediate holding vehicles
- IFM04160: The genuine diversity of ownership condition
- IFM04170: The corporate ownership condition
- IFM04180: The loan creditor condition
- IFM04190: The balance of business condition
- Close sectionIFM04200: Property authorised investment funds (PAIFs): process and effects of entry into the PAIF regime
- IFM04210: Overview of process for entry
- IFM04220: Giving notice to enter
- IFM04230: Quashing notices
- IFM04240: Advance clearance procedure for genuine diversity of ownership
- IFM04250: Stamp duty land tax relief (conversion of authorised unit trusts)
- IFM04260: Effects of entry into the PAIF regime
- IFM04270: VAT implications
- IFM04280: Property authorised investment funds (PAIFs): seeding relief
- Close sectionIFM04300: AIFs: Property authorised investment funds (PAIFs): tax treatment of PAIFs and distributions
- IFM04310: General principles
- IFM04320: Calculation of the net income for the tax-exempt business
- IFM04330: Calculation of the net income for the residual business
- IFM04340: Charge to tax for distributions to holders of excessive rights
- IFM04350: Excess financing costs in a qualified investor scheme (QIS)
- IFM04355: Corporation tax charge where there are excess financing costs in a qualified investor scheme
- IFM04360: Cancellation of tax advantage
- IFM04370: Attribution of distributions
- IFM04372: Attribution of distributions - example 1
- IFM04374: Attribution of distributions - example 2
- IFM04376: Attribution of distributions - notes to examples
- IFM04380: Company tax return
- Close sectionIFM04400: Property authorised investment funds (PAIFs): Deducting and accounting for tax from distributions
- IFM04410: Introduction
- IFM04420: Deduction of tax from distributions made by PAIFs
- IFM04430: Gross payments of property income distributions
- IFM04440: The reasonable belief test with respect to gross payments
- IFM04450: Certificates of deduction of tax
- IFM04460: Submitting returns
- IFM04470: Collection and payment of tax
- Close sectionIFM04500: Property authorised investment funds: breaches of conditions
- IFM04510: Introduction
- IFM04520: Breach of the genuine diversity of ownership condition
- IFM04530: Breach of the corporate ownership condition
- IFM04540: Breach of the loan creditor condition
- IFM04550: Breach of the balance of business condition
- IFM04560: Multiple breaches of separate condition
- IFM04570: Information requirements
- Close sectionIFM04600: Leaving the property authorised investment fund (PAIF) regime
- Close sectionIFM04100: Introduction and conditions of membership for the regime
- Close sectionIFM05000: Investors in property authorised investment funds (PAIFs)
- Close sectionIFM06000: Tax elected funds (TEFs)
- Close sectionIFM06100: Tax elected funds (TEFs): introduction and conditions of membership for the TEF regime
- Close sectionIFM06200: Tax elected funds (TEFs): application process and effects of entry to the TEF regime
- Close sectionIFM06300: Tax elected funds (TEFs): tax treatment and distributions made by TEFs
- Close sectionIFM06400: Tax elected funds (TEFs): provisions for providing tax information to investors
- Close sectionIFM06500: Tax elected funds (TEFs): breaches of conditions
- IFM06510: Introduction
- IFM06520: General provisions
- IFM06530: Breach of the property condition, the genuine diversity of ownership condition & the scheme documentation condition
- IFM06540: Breach of the loan creditor condition
- IFM06550: Multiple breaches of separate conditions
- IFM06560: Information requirements
- Close sectionIFM06600: Tax elected funds (TEFs): leaving the TEF regime
- Close sectionIFM07000: Investors in tax elected funds (TEFs): tax treatment of distributions
- IFM07100: Introduction
- IFM07200: Trail commission
- IFM07300: TEF distributions (dividends) - investors within the charge to corporation tax
- IFM07400: TEF distributions (non-dividend) - investors within the charge to corporation tax (CT): distributions
- IFM07500: Investors within the charge to corporation tax (CT): disposals
- IFM07600: Investors in tax elected funds (TEFs): TEF distributions (dividends): investors within the charge to income tax
- IFM07700: TEF distributions (non-dividend): investors within the charge to income tax
- IFM07800: Investors within the charge to income tax (IT): disposals
- Close sectionIFM08000: Authorised Contractual Schemes: Contents
- Close sectionIFM08100: Authorised Contractual Schemes (ACS): Introduction and Overview
- Close sectionIFM08200: Co-ownership Authorised Contractual Schemes (CoACS): Information Requirements
- IFM08210: Co-ownership Authorised Contractual Schemes (CoACS): Information requirements: Introduction
- IFM08220: Co-ownership Authorised Contractual Schemes (CoACS): Information requirements: Providing information to investors
- IFM08230: Co-ownership Authorised Contractual Schemes (CoACS): Information requirements: Providing information to HMRC
- IFM08240: Co-ownership Authorised Contractual Schemes (COACS): Information requirements: Penalties for failing to provide information
- Close sectionIFM08300: Co-ownership Authorised Contractual Schemes: Providing Tax Information to Investors: Contents
- IFM08310: Co-ownership Authorised Contractual Schemes (CoACS): Providing Tax Information to Investors: Introduction and Overview
- IFM08320: Co-ownership Authorised Contractual Schemes (CoACS): Capital allowances: introduction
- IFM08330: Co-ownership Authorised Contractual Schemes (CoACS): Calculation of capital allowances
- IFM08340: Co-ownership Authorised Contractual Schemes (CoACS): Capital allowances: effect of election for purchasers
- IFM08350: Co-ownership Authorised Contractual Schemes (CoACS): Income arising in offshore funds: introduction
- IFM08360: Co-ownership Authorised Contractual Schemes (CoACS): Income arising in offshore funds: income arising to investors in a CoACS
- Close sectionIFM08400: Authorised Contractual Schemes: Other tax issues: contents
- Close sectionifm08500: Taxation of UK investors in authorised contractual schemes: income: contents
- IFM08510: Taxation of income arising to UK investors in authorised contractual schemes (ACS): Introduction
- IFM08520: Co-ownership authorised contractual schemes (ACS): Investors within the charge to Income Tax
- IFM08530: Taxation of income arising to UK investors in ACS: investors within the charge to Corporation Tax
- IFM08540: Taxation of UK investors in Authorised Contractual Schemes (ACS): property income
- Close sectionIFM08600: Taxation of UK investors in Authorised Contractual Schemes: chargeable gains: contents
- IFM08610: Co-ownership Authorised Contractual Schemes (CoACS): Chargeable Gains: Introduction
- IFM08620: Co-ownership Authorised Contractual Schemes (CoACS): Chargeable Gains calculation
- IFM08630: Co-ownership Authorised Contractual Schemes (CoACS): Chargeable Gains: part-disposals
- IFM08640: Co-ownership Authorised Contractual Schemes (CoACS): Chargeable Gains: Insurance Companies
- IFM08650: Partnership Authorised Contractual Schemes: Chargeable Gains
- Close sectionIFM10000: Taxation of unauthorised unit trusts (UUTs): contents
- IFM10100: Introduction to Unauthorised Unit Trusts (UUTs)
- IFM10200: Taxation of exempt unauthorised unit trusts (EUUTs): contents
- IFM10300: Taxation of a non-exempt unauthorised unit trust (NEUUT): contents
- IFM10400: Tax treatment of a mixed unauthorised unit trust (MUUT)
- IFM10500: Stamp duty and Stamp duty reserve tax (SDRT)
- IFM10600: VAT
- IFM10700: Double taxation treaties
- Close sectionIFM11000: Investors in unauthorised unit trusts (UUTs): Contents
- IFM11100: Introduction
- IFM11200: Investors in an exempt unauthorised unit trust (EUUT) - distributions
- IFM11300: Investors in an exempt unauthorised unit trust (EUUT) - disposals
- IFM11400: Investors in a non-exempt unauthorised unit trust (NEUUT) - distributions
- IFM11500: Investors in a non-exempt unauthorised unit trust (NEUUT) - disposals
- IFM11600: Investors in a mixed unauthorised unit trust (MUUT) - distributions
- IFM11700: Investors in a mixed unauthorised unit trust (MUUT) - disposals
- IFM11800: Non-resident investors in an exempt unauthorised unit trust (EUUT)
- Close sectionIFM12000: Offshore funds: introduction and contents
- IFM12100: Introduction: background to the treatment of UK investors in offshore funds
- IFM12200: Offshore Funds: Definition of an offshore fund: overview
- IFM12220: Offshore Funds: Definition of an offshore fund: Meaning of ‘offshore fund’
- IFM12230: Offshore Funds: Definition of an offshore fund: Meaning of ‘mutual fund’
- IFM12240: Offshore Funds: Definition of an offshore fund: exceptions to the meaning of mutual fund
- IFM12250: Transparent entities
- IFM12260: Umbrella funds and protected cell companies
- IFM12270: Classes of interest
- IFM12280: Definition of an offshore fund: particular arrangements
- IFM12300: Offshore Funds: introduction: non-reporting funds
- IFM12400: Offshore Funds: Reporting Funds
- IFM12500: Offshore Funds: Reporting funds: computation of reportable income
- IFM12600: Offshore Funds: Reporting funds: reporting obligations
- IFM12700: Offshore Funds: Reporting funds: breaches of reporting fund conditions
- IFM12800: Offshore Funds: Reporting funds: leaving the regime
- Close sectionIFM13000: Offshore Funds: Participants in offshore funds
- IFM13100: Introduction: background to the treatment of UK investors in offshore funds
- Close sectionIFM13200: Participants within the charge to corporation tax
- Close sectionIFM13300: Offshore Funds: participants in offshore funds: participants within the charge to income tax
- IFM13310: Introduction
- IFM13340: Reporting funds that become non-reporting funds: deemed disposal election
- IFM13350: Income and distributions from non-reporting funds
- IFM13360: Income and distributions from non-reporting funds
- IFM13370: Disposals: reporting funds
- IFM13380: Disposals: non-reporting funds
- Close sectionIFM13400: Offshore Funds: participants in offshore funds: the charge to tax on disposal of an interest in a non-reporting fund
- IFM13410: Overview
- IFM13412: The charge to tax
- IFM13414: The charge to tax: income tax
- IFM13416: The charge to tax: corporation tax
- IFM13420: Non-resident settlements
- IFM13425: Effect of section 87 attribution rules on offshore income gains arising in non-resident settlement structures
- IFM13430: Effect of residence / domicile of beneficiary on offshore income gains arising in non-resident settlement structures that are attributed under section 87 TCGA rules
- IFM13432: Allocating capital payments between offshore income gains and chargeable gains arising in non-resident settlements
- IFM13434: Example showing how a UK resident but non-UK domiciled beneficiary may not be chargeable to tax on an offshore income gain arising in a non-resident settlement prior to 6 April 2008
- IFM13436: Example showing how a UK resident but non-UK domiciled beneficiary may benefit from a ‘rebasing’ election
- IFM13438: Example showing how a UK resident but non-UK domiciled beneficiary may not benefit from a ‘rebasing’ election
- IFM13440: Transfer of assets abroad
- IFM13442: Offshore income gains arising to certain non-resident companies
- IFM13444: Application of other TCGA provisions
- Close sectionIFM13450: Exceptions to the charge to tax
- IFM13452: General
- IFM13454: Interests treated as loan relationships
- IFM13456: Interests treated as derivative contracts
- IFM13458: Intangible fixed assets
- IFM13460: Excluded indexed securities
- IFM13462: Rights arising under a policy of insurance
- IFM13464: Trading stock
- IFM13466: Long-term insurance funds
- IFM13468: Non-participating loans
- IFM13470: Interests in certain transparent funds
- IFM13472: Rights in certain existing holdings
- IFM13474: Charitable companies & charitable trusts
- IFM13476: Registered pension schemes
- IFM13478: Unlisted trading company exception
- Close sectionIFM13500: Offshore Funds: investors in non-reporting funds: computation of offshore income gain
- Close sectionIFM13600: Offshore Funds: deduction of offshore income gains in computing capital gains
- IFM13700: Participants in transparent offshore funds: amounts derived from capital
- Close sectionIFM14000: Taxation of investment trusts
- IFM14100: Introduction: contents
- IFM14200: Taxation of investment trusts: contents
- IFM14300: Process and effects of entry into the investment trust regime: contents
- IFM14400: Eligibility and approval requirements: contents
- IFM14500: Breaches of eligibility conditions or requirements of regulations
- IFM14600: Double tax treaties
- Close sectionIFM15000: Investors in investment trusts
- Close sectionIFM16000: Exchanges, Mergers, Schemes of Reconstruction
- Close sectionIFM16100: Exchanges, Mergers, Schemes of Reconstruction
- Close sectionIFM16200: Exchanges, Mergers, Schemes of Reconstruction: Collective investment schemes
- IFM16210: Exchanges of units for units in the same collective investment scheme
- IFM16220: Exchange of units for those in another collective investment scheme
- IFM16230: Scheme of reconstruction involving issue of units
- IFM16240: Scheme of reconstruction involving conversion scheme
- IFM16250: Meaning of scheme of reconstruction
- IFM16260: Anti-Avoidance Rule
- IFM16270: Property authorised investment fund and dedicated feeder fund
- Close sectionIFM16300: Exchanges, Mergers, Schemes of Reconstruction; other investment funds
- Close sectionIFM17000: Genuine Diversity of Ownership (GDO)
- IFM17100: Introduction
- IFM17200: When does a genuine diversity of ownership (GDO) condition apply?
- IFM17300: Conditions
- IFM17350: Specific provisions relating to feeder funds
- IFM17355: Specific provisions relating to long-term asset funds
- IFM17370: Particular considerations related to closed-ended funds
- IFM17400: Advance clearance procedure
- IFM18000: Investment transactions - the ‘investment transactions list’
- Close sectionIFM21000: Real Estate Investment Trust : Background: Contents
- IFM21005: Real Estate Investment Trusts : Background: Introduction
- IFM21010: Real Estate Investment Trust : Background: Navigating the Legislation
- IFM21015: Real Estate Investment Trust : Background: Fundamentals: The Ring Fence
- IFM21020: Real Estate Investment Trust : Background: Key Concepts: Property Rental Business
- IFM21025: Real Estate Investment Trust : Background: Key Concepts: Property Rental Business: Excluded Business
- IFM21030: Real Estate Investment Trust : Background: Key Concepts: Property Rental Business: Excluded Business: Owner-Occupied Property
- IFM21035: Real Estate Investment Trust : Background: Key Concepts: Property Rental Business: Excluded Income
- IFM21040: Real Estate Investment Trust : Background: General Definitions Relating To Parts of a UK-REIT
- IFM21045: Real Estate Investment Trust : Background: Creating the Ring Fence
- IFM21050: Overview Of The Regime
- IFM21060: Real Estate Investment Trust : Background : Group REITs - definition of ‘group’ that can be a group REIT
- IFM21070: Real Estate Investment Trust : Background : Group REITs: non-resident group members: property rental business
- IFM21080: Real Estate Investment Trust : Background : Group REITs: non-resident group members: UK property rental business
- Close sectionIFM22000: Real Estate Investment Trust : Conditions and Test : Contents
- IFM22005: Real Estate Investment Trust : Conditions and Tests: Summary
- IFM22010: Real Estate Investment Trust : Conditions And Tests: Company Conditions: Conditions A-C: CTA 2010, s 528(1) - (3)
- IFM22015: Real Estate Investment Trust : Conditions And Tests: Company Conditions: Conditions D-F: CTA 2010, s 528(4) - (9)
- IFM22016: Real Estate Investment Trust : Conditions And Tests: Company Conditions: Condition D: Institutional Investors: CTA 2010, s 528(4A)
- IFM22020: Real Estate Investment Trust : Conditions and Tests: Property Rental Business: Summary
- IFM22025: Real Estate Investment Trust : Conditions And Tests: Property Rental Business Conditions: Condition A: CTA 2010, s 529(1)
- IFM22030: Real Estate Investment Trust : Conditions And Tests: Property Rental Business Conditions: Condition A: Single Property: CTA 2010, s 529(1)
- IFM22033: Real Estate Investment Trust Conditions and Tests: Property rental Business Conditions: Indirectly Held Property: CTA 2010, s 529
- IFM22035: Real Estate Investment Trust : Conditions And Tests: Property Rental Business Conditions: Condition B: CTA 2010, s 529(2)
- IFM22040: Real Estate Investment Trust : Conditions And Tests: Property rental Business Conditions: Condition B: Valuation Of Assets : CTA 2010, s 529(2)
- IFM22050: Real Estate Investment Trust : Conditions and Tests: Distribution Condition: General: CTA 2010, s 530
- IFM22055: Real Estate Investment Trust : Conditions and Tests: Distribution Condition: Legal Impediment: CTA 2010, s 530(3) and (5)
- IFM22060: Real Estate Investment Trust :Conditions And Tests: Distribution Condition: Interaction With 10% Maximum Shareholding Rule: CTA 2010, s 530(6)
- IFM22065: Real Estate Investment Trust : Conditions and Tests: Balance of business Conditions (CTA 2010, s 531)
- IFM22070: Real Estate Investment Trust : Conditions and Tests: Balance of business Conditions: Condition A (CTA 2010, s 531(1)-(4B))
- IFM22071: Real Estate Investment Trust : Conditions and Tests: Balance of business Conditions: Miscellaneous items of profits
- IFM22072: Real Estate Investment Trust : Conditions and Tests: Balance of business Conditions: Condition A - outside the ordinary course of business. (CTA 2010, s 531(4)(c))
- IFM22075: Real Estate Investment Trust : Conditions and Tests: Balance of business Conditions: Condition B (asset test) (CTA 2010, s 531(5)-(9))
- IFM22100: Real Estate Investment Trust : Conditions and tests: maximum shareholding: CTA 2010, s 551- CTA 2010, s 554
- IFM22105: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: definitions
- IFM22106: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: ‘holder of excessive rights’ (HoER) examples
- IFM22110: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: when and how a holder of excessive rights (HoER) charge arises: CTA 2010, s 551
- IFM22113: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: when a holder of excessive rights (HoER) charge arises: examples
- IFM22120: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: nature and amount of charge : CTA 2010, s 551 - CTA 2010, s 552
- IFM22123: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: formula to work out notional income: CTA 2010, s 552
- IFM22125: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: reasonable steps: CTA 2010, s 551(1)(b)
- IFM22130: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: reasonable steps: identifying holders of excessive rights: CTA 2010, s 551(1)(b)
- IFM22135: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: reasonable steps: preventing payment of a distribution to a holder of excessive rights : CTA 2010, s 551(1)(b)
- IFM22140: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: reasonable steps: payment of a distribution where rights to it are transferred: CTA 2010, s 551(1)(b)
- IFM22145: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: reasonable steps: distributions paid in respect of excessive shareholdings: CTA 2010, s 551(1)(b)
- IFM22150: Real Estate Investment Trust : Conditions and Tests: maximum shareholding: reasonable steps: retained distributions: interaction with other rules
- IFM22200: Real Estate Investment Trust : Conditions and Tests: interest cover test (profit: financing cost ratio): CTA 2010, s 543
- IFM22205: Real Estate Investment Trust : Conditions and Tests: interest cover test: consequences of breaching the limit: CTA 2010, s 543
- IFM22300: Real Estate Investment Trust : Group conditions and rules : Financial statements: basics : CTA 2010, s 532 - CTA 2010, s 533
- IFM22305: Real Estate Investment Trust : Group conditions and rules: Financial Statements: Joint Ventures: CTA 2010, s 533 and CTA 2010, s 588
- IFM22315: Real Estate Investment Trust : Group conditions and rules: Financial Statements: property rental business and residual business: general principles
- IFM22320: Real Estate Investment Trust : Group conditions and rules: Financial Statements: property rental business and residual: treatment of entities that are not wholly owned
- IFM22325: Real Estate Investment Trust : Group conditions and rules: Financial Statements: property rental business and residual: intra-group transactions SI2006/2865/Regulation (5)
- IFM22330: Real Estate Investment Trust : Group conditions and rules: Financial Statements: property rental business and residual business: entities treated as opaque
- IFM22335: Real Estate Investment Trust : Group conditions and rules: Financial Statements: property rental business and residual: other entities treated as transparent
- IFM22340: Real Estate Investment Trust : Group conditions and rules: Financial Statements: property rental business and residual: other entities - table
- IFM22345: Real Estate Investment Trust : Group conditions and rules: Financial Statements: property rental business and residual: significant influence : SI2006/2865/Regulation (3)
- IFM22350: Real Estate Investment Trust : Group conditions and rules: Financial Statements: financing costs
- IFM22355: Real Estate Investment Trust : Group conditions and rules: Financial Statements: financing costs
- IFM22360: Real Estate Investment Trust : Group conditions and rules: Financial Statements: UK property rental business
- IFM22365: Real Estate Investment Trust : Group conditions and rules: Financial Statements: UK property rental business: entities that are not wholly owned
- Close sectionIFM23000: Real Estate Investment Trust : Entry to the regime: contents
- IFM23005: Real Estate Investment Trust : Entry to the regime: overview
- IFM23010: Real Estate Investment Trust : Entry to the regime: notice to join: CTA2010/S523 and S524
- IFM23015: Real Estate Investment Trust : Entry to the regime: effects of entry: cessation of business and accounting period: CTA 2010, s 536
- IFM23020: Real Estate Investment Trust : Entry to the regime: effects of entry: deemed sale and reacquisition of assets: CTA2010/S536
- IFM23025: Real Estate Investment Trust : Entry to the regime: entry charge prior to 17th July 2012: outline
- IFM23100: Real Estate Investment Trust : Entry to the regime: effects of entry: capital losses from pre-entry periods: CTA 2010, s 541
- IFM23105: Real Estate Investment Trust : Entry to the regime: effects of entry: trading and other losses from pre-entry periods: CTA 2010, s 541
- IFM23110: Real Estate Investment Trust : Entry to the regime: effects of entry: other expenses etc pre-entry periods: CTA 2010, s 541
- Close sectionIFM24000: Real Estate Investment Trust : Property Rental Income : Contents
- IFM24005: Real Estate Investment Trust : Property rental income : Calculation of property rental business profits: general: CTA 2010, s 599
- IFM24010: Real Estate Investment Trust : Property rental income: capital allowances: general: CTA 2010, s 537
- IFM24015: Real Estate Investment Trust : Property rental income: capital allowances: assets that move between the property rental and residual businesses: CTA 2010, s 555 and CTA 2010, s 557
- IFM24020: Real Estate Investment Trust : Property rental business income: loan relationships and derivative contracts: general: CTA 2010, s 599(3)
- IFM24023: Real Estate Investment Trust : Property rental business income: loan relationships and derivative contracts: interpretation: CTA 2010, s 599(4)
- IFM24025: Real Estate Investment Trust : Property rental business income: loan relationships and derivative contracts: interest and netting off: CTA 2010, s 599(3)
- IFM24028: Real Estate Investment Trust : Property rental business income: loan relationships and derivative contracts: partnership example
- IFM24029: Real Estate Investment Trust : Property rental business losses
- IFM24030: Real Estate Investment Trust : Property rental business income: Property rental business/Trading borderline: general
- IFM24035: Real Estate Investment Trust : Property rental business income: Property rental income/ trading income borderline: specific
- IFM24040: Real Estate Investment Trust : Property rental business income: investment/trading borderline: general
- IFM24045: Real Estate Investment Trust : Property rental business income: investment/trading borderline: development
- IFM24048: Real Estate Investment Trust : Property rental business income: investment/trading borderline: other examples
- IFM24050: Real Estate Investment Trust : Property rental business income: investment/trading borderline: 3 year development rule: CTA 2010, s 556
- IFM24055: Real Estate Investment Trust : Property rental business income: investment/trading borderline: refund of Entry Charge: CTA 2010, s 556(4)
- IFM24060: Real Estate Investment Trust : Property rental business income: investment/trading borderline: 3-year development rule: interpretations: CTA 2010, s 556
- Close sectionIFM24500: Real Estate Investment Trust : Residual Income : Contents
- IFM24505: Real Estate Investment Trust : Residual income: general
- IFM24510: Real Estate Investment Trust : Residual income: disposal of assets used in the property rental business: CTA2010/556
- IFM24515: Real Estate Investment Trust : Residual income: disposal of assets used in the property rental business by way of trade: CTA 2010, s 555
- IFM24520: Real Estate Investment Trust : Residual income: treatment of disposals: three year development rule: CTA 2010, s 556
- Close sectionIFM25000: Real Estate Investment Trust : Capital Gains: Contents
- IFM25005: Real Estate Investment Trust : Capital gains: general : CTA 2010, s 535 and CTA 2010, s 535A
- IFM25006: Real Estate Investment Trust : Capital gains: general : CTA 2010, s 535 and CTA 2010, s 535A
- IFM25007: Real Estate Investment Trust : Capital gains : Indirect disposal of property rental business assets: CTA 2010, s 535A
- IFM25010: Real Estate Investment Trust : Capital gains: computational rules: dual use assets: CTA 2010, s 535
- IFM25013: Real Estate Investment Trust : Capital gains: computational rules: dual use assets: examples
- IFM25015: Real Estate Investment Trust : Capital gains: computational rules: movement of assets out of the property rental business: CTA 2010, s 555 and CTA 2010, s 556
- IFM25020: Real Estate Investment Trust : Capital gains: computational rules: movement of assets into the property rental business: CTA 2010, s 557
- IFM25025: Real Estate Investment Trust : Capital gains: computational rules: transfers of assets within a group where the principal company is a single company UK-REIT: TCGA 1992, s 171 and TCGA 1992, s 171A
- IFM25030: Real Estate Investment Trust : Capital gains: computational rules: transfers of assets within a Group REIT (TCGA 1992, s 171 and TCGA 1992, s 171A)
- IFM25033: Real Estate Investment Trust : Capital gains: computational rules: Company ceasing to be a member of a group (disposal of shares): CTA 2010, s 559 and CTA 2010, s 579
- IFM25035: Real Estate Investment Trust : Capital gains: computational rules: company ceasing to be a member of a group (TCGA 1992, s 179)
- IFM25037: Real Estate Investment Trust : Capital gains: computational rules: company ceasing to be a member of a group (TCGA 1992, s 179): examples
- IFM25041: Real Estate Investment Trust : Capital gains: demerger of property rental business: CTA 2010, s 558 and 559
- IFM25045: Real Estate Investment Trust : Capital gains: company reconstructions (TCGA 1992, s 135)
- IFM25050: Real Estate Investment Trust : Capital gains: transactions within groups: examples (1)
- IFM25055: Real Estate Investment Trust : Capital gains: transactions within groups: examples (2)
- Close sectionIFM26000: Real Estate Investment Trust : Leaving the regime: contents
- IFM26005: Real Estate Investment Trust : Leaving the regime: overview
- IFM26010: Real Estate Investment Trust : Leaving the regime: effects of cessation: on property rental business and accounting periods: CTA 2010, s 579
- IFM26013: Real Estate Investment Trust : Leaving the regime: effects of cessation: availability of relief for losses: CTA 2010, s 579 and CTA 2010, s 541
- IFM26015: Real Estate Investment Trust : Leaving the regime: effects of cessation: deemed sale and reacquisition of assets: CTA 2010, s 579 and CTA 2010, s 580
- IFM26020: Real Estate Investment Trust : Leaving the regime: termination by company/principal company: CTA 2010, s 571
- IFM26025: Real Estate Investment Trust : Leaving the regime: exit by HMRC notice: CTA 2010, s 572
- IFM26030: Real Estate Investment Trust : Leaving the regime: automatic termination: CTA 2010, s 578
- IFM26035: Real Estate Investment Trust : Leaving the regime: early exit: CTA 2010, s 571
- IFM26040: Real Estate Investment Trust : Leaving the regime: early exit: company notice within ten years of joining: CTA 2010, s 581
- IFM26045: Real Estate Investment Trust : Leaving the regime: early exit: Direction by HMRC
- Close sectionIFM27000: Real Estate Investment Trust : Breaches of conditions: contents
- IFM27005: Real Estate Investment Trust : Breaches of conditions: overview
- IFM27010: Real Estate Investment Trust : Breaches of conditions: information requirements: CTA 2010, s 561 and 578(3); SI 2006/2864/Reg 11
- IFM27015: Real Estate Investment Trust : Breaches of conditions: Admitted to trading, “listed” or traded and ‘not close’ requirements): take-overs: CTA 2010, s 562(2), 562A(5), 562B(3) and 562C(3)
- IFM27020: Real Estate Investment Trust : Breaches of conditions: Company Condition D (‘not close’): actions of others: CTA 2010, s 562A(6)
- IFM27025: Real Estate Investment Trust : Breaches of conditions: Company Conditions C (admitted to trading) and D (‘not close’) and other condition relating to shares (“listed” or traded): other breaches: CTA 2010, s 562(5) , CTA 2010, s 562A(4) and CTA 2010, s 562B(2)
- IFM27030: Real Estate Investment Trust : Breaches of conditions: number and value of properties: CTA 2010, s 563 and CTA 2010, s 575
- IFM27035: Real Estate Investment Trust : Breaches of conditions: number and value of properties: examples: CTA 2010, s 563 and CTA 2010, s 575
- IFM27045: Real Estate Investment Trust : Breaches of conditions: Distribution Condition: general: CTA 2010, s 564
- IFM27050: Real Estate Investment Trust : Breaches of conditions: Distribution Condition: tax charge for failure: CTA 2010, s 564 - CTA 2010, s 565
- IFM27055: Real Estate Investment Trust : Breaches of conditions: Balance of business Conditions: CTA 2010, s 568
- IFM27060: Real Estate Investment Trust : Breaches of conditions: Balance of business Conditions: repeat, multiple and serious breaches: CTA 2010, s 576 and CTA 2010, s 577
- IFM27065: Real Estate Investment Trust : Breaches of conditions: multiple breaches: CTA 2010, s 577
- IFM27070: Real Estate Investment Trust : Breaches of conditions: multiple breaches: example
- IFM27071: Real Estate Investment Trust : Breaches of conditions: serious breaches: CTA 2010, s 574
- IFM27075: Real Estate Investment Trust : Breaches of conditions/rules: summary table
- Close sectionIFM28000: Real Estate Investment Trust : Distributions: Contents
- IFM28005: Real Estate Investment Trust : Distributions: general
- IFM28008: Real Estate Investment Trust : Distributions: The distribution requirement : CTA 2010, s 530
- IFM28010: Real Estate Investment Trust : Distributions: attribution rules: CTA 2010, s 550
- IFM28015: Real Estate Investment Trust : Distributions: attribution rules: category (a) - 100% UK REIT investment profits: CTA 2010, s 550(2)(a)
- IFM28020: Real Estate Investment Trust : Distributions: attribution rules: category (aa) - 90% mandatory distribution: CTA 2010, s 550(2)(aa)
- IFM28023: Real Estate Investment Trust : Distributions: attribution rules: category (a) and (aa) - mandatory distribution: examples
- IFM28025: Real Estate Investment Trust : Distributions: attribution rules: category (b) - income from taxable activities: CTA 2010, s 550(2)(b)
- IFM28028: Real Estate Investment Trust : Distributions: attribution rules: category (b) - income from taxable activities: examples
- IFM28030: Real Estate Investment Trust : Distributions: attribution rules: category (c) - other income of the property rental business: CTA 2010, s 550(2)(c)
- IFM28033: Real Estate Investment Trust : Distributions: attribution rules: category (c) - other income of the property rental business: consequences of Category (b) choices: example
- IFM28034: Real Estate Investment Trust : Distributions: attribution rules: category (c) - other income of the property rental business: examples
- IFM28035: Real Estate Investment Trust : Distributions: attribution rules: category (d) - gains of the property rental business: CTA 2010, s 550(2)(d)
- IFM28040: Real Estate Investment Trust : Distributions: attribution rules: category (e) - other: CTA 2010, s 550(2)(e)
- IFM28045: Real Estate Investment Trust : Distributions: attribution rules: interim distributions: CTA 2010, s 550
- IFM28050: Real Estate Investment Trust : Distributions: attribution rules: first accounting period as a UK-REIT: CTA 2010, s 550
- IFM28053: Real Estate Investment Trust : Distributions: attribution rules: first accounting period as a UK-REIT: example
- IFM28054: Real Estate Investment Trust : Distributions: attribution rules: Takeovers/mergers: CTA 2010, s 550
- IFM28055: Real Estate Investment Trust : Distributions: attribution rules: leaving the regime and liquidations: CTA 2010, s 550 and CTA 2010, s 548(2) and (4)
- IFM28060: Real Estate Investment Trust : Distributions: administration by UK-REIT: SI2006/2867
- IFM28065: Real Estate Investment Trust : Distributions: administration: quarterly returns: SI2006/2867
- IFM28070: Real Estate Investment Trust : Distributions: administration: reconciliations: SI2006/2867
- IFM28075: Real Estate Investment Trust : Distributions: administration: attribution: example
- IFM28080: Real Estate Investment Trust : Distributions: administration: quarterly returns and reconciliation: example
- IFM28085: Real Estate Investment Trust : Distributions: administration: attributions and reconciliation: summary of examples
- IFM28090: Real Estate Investment Trust : Distributions: administration: attributions and reconciliation: summary of examples
- IFM28095: Real Estate Investment Trust : Distributions: administration: attributions and reconciliation: summary of examples
- IFM28115: Real Estate Investment Trust : Distributions: administration: quarterly returns: due dates, assessments etc
- IFM28120: Real Estate Investment Trust : Distributions: administration: quarterly returns: mistakes : SI2006/2867
- IFM28125: Real Estate Investment Trust : Distributions: administration: gross payment: SI2006/2867/Reg 7
- IFM28200: Real Estate Investment Trust : Distributions: manufactured payments: background
- IFM28210: Real Estate Investment Trust : Distributions: manufactured payments: manufactured PIDs
- IFM28220: Real Estate Investment Trust : Distributions: manufactured payments: deduction of tax
- IFM28230: Real Estate Investment Trust : Distributions: dividend strips
- Close sectionIFM29000: Real Estate Investment Trust : Miscellaneous: contents
- IFM29005: Real Estate Investment Trust : Miscellaneous: funds awaiting reinvestment : CTA 2010, s 547
- IFM29010: Real Estate Investment Trust : Miscellaneous: indirect ownership of property
- IFM29015: Real Estate Investment Trust : Miscellaneous: indirect ownership of property: Balance of business conditions
- IFM29020: Real Estate Investment Trust : Miscellaneous: indirect ownership of property: Exemption from tax
- IFM29025: Real Estate Investment Trust : Miscellaneous: indirect ownership of property: Property rental business conditions
- IFM29030: Real Estate Investment Trust : Miscellaneous: indirect ownership of property: summary
- IFM29040: Real Estate Investment Trust : Miscellaneous: indirect ownership of property: non-resident unit trusts
- IFM29100: Real Estate Investment Trust : Miscellaneous: insurance companies holding shares in a UK-REIT: TCGA 1992, s 212
- IFM29200: Real Estate Investment Trust :Miscellaneous: transfers within a group: TCGA 1992, s 171
- IFM29220: Real Estate Investment Trust : Miscellaneous: availability of group relief: CTA 2010, s 601
- IFM29225: Real Estate Investment Trust : Miscellaneous: availability of group relief: example
- IFM29230: Real Estate Investment Trust : Miscellaneous: controlled foreign companies
- IFM29300: Real Estate Investment Trust :Cancellation of a tax advantage: CTA 2010, s 545
- IFM29400: Real Estate Investment Trust :Prescribed arrangements: 2009/3315 - Real Estate Investment Trusts (Prescribed Arrangements) Regulations 2009
- Close sectionIFM30000: Real Estate Investment Trust : Joint Ventures : Contents
- IFM30005: Real Estate Investment Trust : Joint ventures: introduction
- IFM30015: Real Estate Investment Trust : Joint ventures: conditions to give a Joint Venture Look-Through Notice: CTA 2010, s 586 and CTA 2010, s 587
- IFM30020: Real Estate Investment Trust : Joint ventures: Joint Venture Look-Through Notice: requirements : CTA 2010, s 586 and CTA 2010, s 587
- IFM30025: Real Estate Investment Trust : Joint ventures: Joint Venture Look-Through Notice: effects of notice: CTA 2010, s 588 and CTA 2010, s 589
- IFM30027: Real Estate Investment Trust : Joint ventures: financial statements: CTA 2010, s 592, CTA 2010, s 593 CTA 2010, s 588 and CTA 2010, s 589
- IFM30030: Real Estate Investment Trust : Joint ventures: Joint Venture Look-Through Notice: Tax-exempt business and other conditions
- IFM30040: Real Estate Investment Trust : Joint ventures: Joint Venture Look-Through Notice: cessation of look through treatment: CTA 2010, s 590
- IFM30045: Real Estate Investment Trust : Joint ventures: Joint Venture Look-Through Notice: change in percentage interest in joint venture company
- IFM30050: Real Estate Investment Trust : Joint ventures: Joint Venture Look-Through Notice: miscellaneous
- Close sectionIFM36000: Disguised investment management fees: Contents
- IFM36100: Overview: Contents
- IFM36200: Deemed trade: Contents
- IFM36300: Disguised fees: Contents
- IFM36400: Co-investment: Contents
- IFM36500: Carried interest and profit related returns: Contents
- IFM36600: Anti-avoidance
- IFM36700: Avoidance of double taxation: Contents
- IFM36800: Returning sums chargeable under the disguised investment management fees (DIMF) rules
- IFM36900: Glossary of terms
- Close sectionIFM37000: Carried interest: Contents
- IFM37100: Overview: Contents
- IFM37200: Charging provisions: Contents
- IFM37300: Foreign chargeable gains: Contents
- IFM37400: Prevention of double taxation: Contents
- IFM37500: Anti-avoidance
- IFM37600: Interaction with Disguised Investment Management Fees rules
- IFM37700: Accruals basis elections: contents
- Close sectionIFM40000: Qualifying Asset Holding Companies: Contents
- IFM40100: Overview: Contents
- IFM40200: Eligibility: contents
- IFM40300: Becoming a QAHC: contents
- IFM40400: Ceasing to be a QAHC: contents
- IFM40500: Group issues: contents
- IFM40600: Other tax issues: contents
- IFM40700: Treatment of certain payments: contents
- IFM40800: Overseas property business: contents
- IFM40900: Gains exemption: contents
- IFM41000: Remittance basis: contents
- IFM41100: Stamp duty and SDRT: contents
- IFM41200: Administrative requirements: contents