GREIT09030 – Miscellaneous: indirect ownership of property: summary for Group REITs
This table summarises the treatment for different types of entity by reference to the various regime conditions and rules for a Group REIT. For single company UK-REITs, see GREIT09035.
| Entity holding property | Income and gains | Property conditions | Balance of business | Entry Charge |
| Member of TCGA group | Arising from qualifying property are tax-exempt | Qualifying property counts | Line-by-line consolidation | Market value of qualifying property |
| Company with JVLT notice in place (see GREIT13000) | Arising from qualifying property are tax-exempt | Qualifying property counts | Line-by-line consolidation | Market value of qualifying property |
| AUTs and other non-transparent entities* | Taxable | Ignored | I > 20%
Line-by-line consolidation | Not applicable |
| I = 20%
Value of shares /dividends non ring-fence asset /income |
||||
| Transparent entities** | Arising from qualifying property are tax-exempt | Unlikely to count | I > 20%
Line-by-line consolidation | Market value of qualifying property |
| I = 20%
Value of shares /dividends non ring-fence asset /income |
*includes companies that are not members of the TCGA group,
such as OEICs
**including partnerships & overseas unit trusts –
for more information on non-resident unit trusts, see
GREIT09040.
For transparent entities, the tax-exempt income, gains and
the Entry Charge arise to the members of the group which have an
interest in the entity.
For other entities, such as a member of a TCGA group or a
joint venture company, the Entry Charge is payable by the entity
itself.
