Jurisdiction(s):
United Kingdom

Key definition

REIT definition

What does REIT mean? A Real Estate Investment Trust (REIT) is a vehicle used to hold and operate a property rental business, enabling investors to access real estate returns through a listed, tax‑efficient structure. In the UK, the regime is statutory (Part 12, Corporation Tax Act 2010 and regulations); Ireland has a parallel statutory regime (Part 25A, Taxes Consolidation Act 1997). Key features include: exemption from corporation tax on profits and gains of the qualifying property rental business; mandatory distribution of most rental profits to shareholders (UK: at least 90%; Ireland: at least 85%); “balance of business” tests requiring at least 75% of assets and...

UK REITs: Indirect property ownership and joint ventures - tax treatment, JPUTs, partnerships, companies, look-through elections and conditions

Published by a LexisNexis Tax expert

Practice notes

This Practice Note considers the circumstances in which a UK Real estate investment trust (REIT, described in the tax legislation as a UK REIT) holds property indirectly through a structure such as a partnership, offshore unit trust or company. It then turns to the scenario where a REIT participates in property via a joint venture company (or a group of companies).

For an overall summary of the REIT regime, see Practice Note: REITs—summary of the tax regime. Other specific aspects of the regime are explored in greater depth in the following Practice Notes:

REITs—the conditions and tests
REITs—tax treatment of the REIT and its shareholders
REITs—breaches and exit

Indirect ownership of property

REITs may hold non-direct interests in property via vehicles including partnerships, offshore unit trusts or companies. The tax analysis for a REIT of such indirect holdings hinges on the legal character of the relevant vehicle. A helpful table summarising the treatment for different categories of entity is provided at IFM29030...

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Martin Shah

Simmons & Simmons

Martin is a partner in the corporate tax group at Simmons & Simmons. His broad based practice encompasses financial markets, corporate, real estate (including structured real estate) and commercial work, with an emphasis on clients in the asset management & investment funds and financial institutions sectors. His focus includes advising on funds and other investment products, together with structural tax issues for asset management, banking and insurance clients.Martin leads the financial services tax practice which won European Financial Services Tax Team of the Year at the International Tax Review European Awards in 2011 and 2013. He is rated in the latest Legal 500 and Chambers directories ("very strong" in his defence of clients’ interests and can be relied upon to be "robust in difficult circumstances") for corporate tax and endorsed by PLC Which Lawyer?.Martin is a regular participant at the...

Web page updated on 22/05/2026

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