REITs are listed property investment companies or groups which are not liable to corporation tax on their rental income or capital gains arising from the disposal of assets used in their property rental business.
As a UK REIT, LondonMetric Property Plc is exempted from corporation tax on rental income and gains on the sale of UK investment properties, but is required to distribute 90% of its property rental income (being gross rental income after adjusting for various items including capital allowances, finance costs and overheads) as a Property Income Distribution (PID).
Profits distributed as PIDs are potentially fully taxable in shareholders’ hands as property rental income. PIDs are normally paid out after deduction of basic rate tax at source, which the REIT pays to HMRC on behalf of the shareholder.
However, certain categories of shareholder are entitled to receive PIDs without suffering withholding tax: these are mainly UK resident companies, UK public bodies, UK charities, UK pension funds and managers of ISAs, PEPs and Child Trust Funds.
If you qualify to receive your PID without deduction of withholding tax, you should complete one of the attached forms depending on whether or not you are the beneficial owner of your shareholding or an intermediary. The completed form should be sent to the Company registrars:
34 Beckenham Road
Most shareholders, including all individuals and all non-UK residents, do not qualify for gross payment and should not complete the forms. Unlike withholding tax on interest, it is unlikely that a shareholder resident outside the UK can obtain advance clearance for the PID to be paid gross.
Other dividends paid by REITs out of non-property rental activities are treated as ordinary dividends and are not subject to withholding tax.
Shareholders who are in any doubt about their tax position, or who are subject to tax in a jurisdiction other than the United Kingdom, should consult their own appropriate independent professional adviser, particularly concerning their tax liabilities on PIDs to determine whether they are entitled to claim any repayment of tax, and, if so, the procedure for so doing.
Non-UK resident shareholders in countries with double tax treaties with the UK which provide for withholding tax on dividends at rates lower than 22 per cent, may be able to make claims for repayment of the difference from HM Revenue & Customs, Residency, Fitz Roy House, PO Box 46, Nottingham, England, NG2 1BD.
Withholding tax exemption claim forms
Beneficial Owner Declaration of Eligibility for Gross PID Payments from UK REIT
Intermediary Declaration of Eligibility for Gross PID Payments from UK REIT