Corporation Tax Act 2010

Attribution of distributions U.K.

550 Attribution of distributions U.K.

(1) Subsection (2) applies to—

(a) distributions made by the principal company of a group UK REIT, and

(b) distributions made by a company UK REIT.

(2) The distributions are to be attributed—

(a) first, to payments in satisfaction of the condition in section 530 (distribution of profits),

(b) second, so far as the company determines, to distribution of amounts which derive from activities of a kind in respect of which corporation tax is chargeable in relation to income,

(c) third, to distribution of profits of property rental business (calculated in accordance with section 599),

(d) fourth, to distribution of relevant non-chargeable gains, and

(e) fifth, to other distributions.

(3) In subsection (2)(d) “relevant non-chargeable gains” means—

(a) in the case of a group, gains accruing to property rental business of a member of the group, and

(b) in the case of a company, gains accruing to property rental business of the company,

which as a result of section 535 are not chargeable gains.