Corporation Tax Act 2010 section 519

"Property rental business"

Section 519 defines the term "property rental business" for the purposes of the REIT regime in Part 12 of the Corporation Tax Act 2010.

  • Property rental business covers both UK property business and overseas property business as defined in sections 205 and 206 of CTA 2009.
  • Income and expenses from tied premises (such as pubs tied to a brewery) that are treated as trading income under CTA 2009 should be ignored — they still count as property rental business for REIT purposes.
  • Certain exclusions apply: lettings by joint venture companies or joint venture group members, businesses of a specified class, and businesses producing income of a specified class are all carved out from the definition.
  • Where a non-UK company is a member of a group, its business qualifies as property rental business if it would do so had it been carried on by a UK company — ensuring worldwide property rental activities are captured.

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