Corporation Tax Act 2010 section 549

Distributions: supplementary

Section 549 sets out exceptions to the normal tax treatment of distributions from UK REITs, defines what counts as a "relevant distribution," and explains how shareholders should treat those distributions for tax purposes.

• Certain shareholders — including traders taxed on distributions as trading income, securities dealers, and individual or corporate Lloyd's members — are excluded from the standard REIT distribution tax rules in section 548
• Stock dividend income rules do not apply to relevant distributions of exempt profits received by shareholders from UK REITs
• A "relevant distribution" means a distribution of property rental business profits from either a group UK REIT's principal company or a single-company UK REIT, but excludes certain distributions between UK REITs that are distributions of exempt profits
• Relevant distributions of exempt profits received by a shareholder are treated as profits of a single, separate property business, distinct from any other UK or overseas property business the shareholder may carry on