Corporation Tax Act 2010 section 601

Availability of group reliefs

Section 601 requires the property rental business of a group UK REIT to be treated as a separate group from its other activities when applying various group relief and group transfer provisions.

• A group UK REIT's property rental business is treated as its own distinct group for the purposes of key group-related tax provisions
• This ring-fenced property rental group is kept separate from the pre-entry group, the residual (non-property) business of the REIT group, and any post-cessation group
• The separation applies across a wide range of provisions including intra-group asset transfers, gain or loss reallocations, loan relationships, derivative contracts, intangible assets, and group relief (including carried-forward losses)
• The effect is to prevent group reliefs and tax-neutral transfers from being used to shift gains, losses or other amounts between the tax-exempt property rental business and the taxable residual business