Section 518: Introduction to Part
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”.