Revenue eBrief No. 093/21
04 May 2021
Real Estate Investment Trusts (REITs)
Tax and Duty Manual Part 25a-00-01, which provides guidance on the taxation of Real Estate Investment Trusts (REITs), has been updated to reflect changes made by Finance Act 2019. The changes are in respect of:
- Applying the "wholly and exclusively" test when calculating profits available for distribution as provided for by section 705HA
- Use of funds raised and disposal proceeds as provided for by section 705I and section 705IA.
The guidance now also addresses the interaction of the Parent / Subsidiary Directive and the special REIT provisions in respect of the taxation of non resident shareholders.