1593.This section is an overview of the Part. It is based on section 103 of FA 2006.
1594.Subsection (1) sets out the “bargain” which is entered into by a group of companies on becoming a UK REIT. If the group meets certain conditions it benefits from an exemption from corporation tax (and, through the operation of section 520(3), an exemption from income tax for non-UK companies) for profits and gains of property rental business. This benefit comes with the following liabilities:
an entry charge (section 538),
a requirement that the principal company of a group deducts sums representing income tax in respect of distributions made to shareholders (section 973 of ITA and SI 2009/2036), and
the treatment of such distributions as profits of a UK property business rather than dividend incomein the hands of shareholders (section 548).
1595.Subsection (2) makes similar provision for companies which enter the UK REIT regime other than as part of a group.
1596.Subsection (3) contains signposts to the remaining Chapters of the Part.
1597.Subsection (4) defines “UK REIT”.