GREIT09035 – Miscellaneous: indirect ownership of property: summary for single company REITs
This table summarises the treatment for different types of entity by reference to the various regime conditions and rules for a single company REIT. For Group REITs, see GREIT09030.
| Entity holding property | Income & gains | Property conditions | Balance of business | Entry Charge |
| Member of TCGA group | Taxable | Ignored | Value of shares /dividends non ring-fence asset /income | Not applicable |
| 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 | Value of shares /dividends non ring-fence asset /income | Not applicable |
| Transparent entities** owned by UK-REIT itself | Arising from qualifying property are tax-exempt | Unlikely to count | Value of assets held by entity and income arising to entity count | Market value of qualifying property |
| Transparent entities** owned UK-REIT subsidiary | Taxable | Ignored | Property and income included in value of subsidiary | Not applicable |
*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 and gains
arise to C (tax-exempt) and the Entry Charge arises to C
(residual).
For a joint venture company with a JVLT notice in place, the
Entry Charge is payable by the joint venture company.
