Revenue Note for Guidance
(1) This section provides for the taxation of shareholders where a REIT or group REIT pays a distribution in the form of a property income dividend.
(2) A corporate shareholder is chargeable to tax under Case IV of Schedule D in respect of a property income dividend.
(3) A property income dividend paid by a member of a group REIT to another member of the same group REIT is exempt from corporation tax.
(4) A section 110 company is chargeable to corporation tax under Case III in respect of a property income dividend.
(5) The trading rate of corporation tax applies to a property income dividend paid to institutional investors.
Relevant Date: Finance Act 2019