Section 550 — Corporation Tax Act 2010: Attribution of distributions

Attribution of distributions 550 1 Subsection (2) applies to—

a distributions made by the principal company of a group UK REIT, and b distributions made by a company UK REIT.

2 The distributions are to be attributed—

a first, to distributions in satisfaction of the requirement of section 530(1)(a) or 530(4)(a) (as the case may be), aa second, to distributions in satisfaction of the requirement of section 530(1)(b) or 530(4)(b) (as the case may be),

b third , so far as the company determines, to distribution of amounts which derive from activities of a kind in respect of which corporation tax is chargeable in relation to income, c fourth , to distribution of profits of property rental business (calculated in accordance with section 599),

d fifth , to distribution of relevant non-chargeable gains, and e sixth , to other distributions.

3 In subsection (2)(d) “ relevant non-chargeable gains ” means—

a in the case of a group, gains accruing to property rental business of a member of the group, and b in the case of a company, gains accruing to property rental business of the company, which as a result of section 535 or 535A are not chargeable gains.

4 In determining the amount of relevant non-chargeable gains for the purposes of this section, section 269ZBA (restriction on deductions) is to be ignored.