If there is a balance remaining after attributing the
distribution to Categories (a) and (b) (see
GREIT08025), the next part of the
distribution is out of income of the property rental business (i.e.
of C (tax-exempt)). This includes the 10% of income of the relevant
accounting period that is not covered by Category (a) as well as
any parts of the 10% from previous years that have not already been
allocated as distributions from Category (c). For information about
the other Categories, see
GREIT08010.
For a Group REIT, the amount attributable to Category (c) is
based on the measure of income that, across the various members of
the group, has been exempted from tax as a consequence of the group
being a UK-REIT. In attributing the distributable reserves of the
principal company therefore it is not by reference to the nature of
the profits as they arise to that company (which will often be as
dividends paid up from subsidiaries that carry on tax- exempt
business), but by reference to the amount of the various kinds of
profit that arise to all the members of the group.
