Phil Nicklin (EY) reviews the draft Finance Bill 2023/24 provisions on real estate investment trusts.
The proposed changes to the REIT regime
Schedule 1 to the draft Finance Bill 2023/24 contains potential changes to the UK REIT regime in CTA 2010 Part 12 namely:
Amendments to the close company condition introducing:
a requirement that certain institutional investors must meet a genuine diversity of ownership condition or a non-close condition (para 2(3));
a new ‘non-close condition’ which makes it clear that it is possible to trace through intermediate holding companies where an institutional investor is the ultimate beneficial owner of the shares in the REIT (para 2(4) to (6)); and
a saving provision to address existing investors who will no longer meet the revised definition of an institutional investor (para 2(8) and (9)).
A relaxation to the REIT group definition to provide that an insurance company can hold an...
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Phil Nicklin (EY) reviews the draft Finance Bill 2023/24 provisions on real estate investment trusts.
The proposed changes to the REIT regime
Schedule 1 to the draft Finance Bill 2023/24 contains potential changes to the UK REIT regime in CTA 2010 Part 12 namely:
Amendments to the close company condition introducing:
a requirement that certain institutional investors must meet a genuine diversity of ownership condition or a non-close condition (para 2(3));
a new ‘non-close condition’ which makes it clear that it is possible to trace through intermediate holding companies where an institutional investor is the ultimate beneficial owner of the shares in the REIT (para 2(4) to (6)); and
a saving provision to address existing investors who will no longer meet the revised definition of an institutional investor (para 2(8) and (9)).
A relaxation to the REIT group definition to provide that an insurance company can hold an...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
