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.