Corporation Tax Act 2010 section 595

Joint venture company liable for additional charge

Section 595 deals with the circumstances in which a joint venture company within a UK REIT structure becomes liable for an additional entry charge to corporation tax.

• An additional tax charge arises when a venturing company becomes the principal company of a group UK REIT and increases its holding in a joint venture company
• The charge also applies when a venturing group increases its holding in a joint venture company to more than 75%
• The amount of the additional charge is based on the "reduced notional amount", which is a specifically defined figure for the purposes of this section
• Once a holding exceeds 75%, the joint venture company becomes a subsidiary covered by the original group REIT notice, and no further joint venture notice can be given