Phil Nicklin (CMS Cameron McKenna Nabarro Olswang) examines the proposed changes introduced by the draft Finance Bill 2021/22 to make the UK REIT regime more attractive.
The proposed changes to the REIT regime
Schedule 1 to the draft Finance Bill 2021/22 contains the first tranche of potential changes to the UK REIT regime in Part 12 of CTA 2010 namely:
a relaxation of the listing condition for REITs owned by ‘institutional investors’ (para 2);
an amendment to the definition of ‘overseas equivalent of a UK REIT’ for the purposes of the relaxation of the close company condition for REITs owned by institutional investors (para 2);
simplified balance of business profits and assets tests utilising an 80% gateway test; and an exclusion for profits resulting from various planning obligations (paras 3 and 4); and
a relaxation of the holder of excessive rights provisions (commonly known as the ‘10% rule’)...
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Phil Nicklin (CMS Cameron McKenna Nabarro Olswang) examines the proposed changes introduced by the draft Finance Bill 2021/22 to make the UK REIT regime more attractive.
The proposed changes to the REIT regime
Schedule 1 to the draft Finance Bill 2021/22 contains the first tranche of potential changes to the UK REIT regime in Part 12 of CTA 2010 namely:
a relaxation of the listing condition for REITs owned by ‘institutional investors’ (para 2);
an amendment to the definition of ‘overseas equivalent of a UK REIT’ for the purposes of the relaxation of the close company condition for REITs owned by institutional investors (para 2);
simplified balance of business profits and assets tests utilising an 80% gateway test; and an exclusion for profits resulting from various planning obligations (paras 3 and 4); and
a relaxation of the holder of excessive rights provisions (commonly known as the ‘10% rule’)...
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:
