Grant Thornton - Manager - UK Corporate Tax - Real Estate Vertical

- Understand key concepts under the corporate interest restriction regime and apply these, including

o Concept of a group

o GRR and FRR and how to apply these

o Deminimis

o Debt cap

o Impact of the PBIE election

o Compliance and admin requirements

- In addition to CIR, understanding other ways interest can be restricted, including

o TP

o Unallowable purpose

o anti hybrid

o late payment

- Understanding different RE structures, including

o Fund structures

o Partnerships

o JPUTs

o REITs

o UK vs non-UK companies for holding UK RE

o REITs

- NRCGT principles, including

o Concept of a UK property rich company

o Latent gains

o Scope of UK tax on gains for non-UK residents (including disposals of shares)

o Exemption and transparency elections application and consequences of making elections in relation to filings

- Capital allowance principles

- Concept of groups for gains and loss purposes, including

o Nil gain nil loss principles

o Degrouping charges

o Group relief claims

- Losses more widely, carry back, carry forward provisions, restriction on carry forward.