GREIT03100 – Entry to the regime: effects of entry: capital losses from pre- entry periods

The table below and at GREIT03105 and GREIT03110 set out the position for utilising losses etc arising in accounting periods up to the date the UK-ICTA rules first apply and which have not been offset against other profits of pre-entry accounting periods, either in the same company or surrendered as group relief.

For single company UK-REITs, the table applies to the company. For Group REITs, the table applies to each company that is a member of the group at the date it joins the regime. It also applies to pre-entry losses etc for companies that join a Group ICTA after the group has joined the regime.

The tables refer to a company before the regime applies to it as C (pre-entry), the part that carries on tax-exempt business after the regime first applies to it as C (tax-exempt) and the part of the company that carries on other taxable activities in that period as C (residual).

References to ‘qualifying’ property business means property business that comes within the definition of ‘property rental business’ as set out in section 104, as modified by Schedule 16 ICTA 2006. The disposals in question are those which took place in accounting periods before the company or group became a UK-ICTA, and which have not been utilised in accounting periods before entry.

Table 1: capital losses

See GREIT03105 and GREIT03110 for Tables 2 and 3: trading and other losses, expenses etc.