IFM04430 - AIFs: Property authorised investment funds (PAIFs): deducting and accounting for tax from distributions: gross payments of property income distributions

Entitlement of investors to receive gross distributions (regulation 69Z24 SI 2006/964)

A PAIF will only make gross payments of Property Income Distributions (PIDs) to an investor who would be entitled to receive a distribution out of the tax-exempt profits of a UK Real Estate Investment Trust (UK REIT) gross 바카라 사이트“ see regulation 7 of SI 2006/2867 and the guidance on REITs.

A PAIF must pay PIDs gross if it reasonably believes that the person beneficially entitled to the payment falls within one of the categories below 바카라 사이트“ see IFM04440.

The following list sets out categories of investor entitled to gross PIDs:

  • UK tax resident company;
  • UK authorised investment fund;
  • non UK tax resident company carrying on a trade through a permanent establishment and which is required to bring the distributions into account for computing its profits for the purposes of calculating its corporation tax;
  • the account manager of an ISA;
  • a local authority;
  • a health service body;
  • a public office or Crown department;
  • a charity or other similar body that has been granted exemption in the same way as a charity;
  • a scientific research organisation;
  • the scheme administrator of a registered pension scheme (eg a SIPP);
  • the sub scheme administrator of a sub scheme which forms part of a split scheme under the Registered Pensions (Splitting of Schemes);
  • a parliamentary pension fund;
  • account provider of a child trust fund;
  • a European investment fund; and
  • certain partnerships (with investors falling in the categories listed above).

See regulation 7 SI 2006/2867 and sections s933 to 937 Income Tax Act 2007 for the full wording relating to the above categories.