Revenue Note for Guidance

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Revenue Note for Guidance

739L Calculating the IREF taxable amount

Summary

This section sets out the formula used to calculate the IREF taxable amount in respect of an IREF taxable event.

Details

(1) The formula is

A X B

– D + E where

C

A is the value of the IREF taxable event which is attributable to the retained profits of the IREF;

B is the retained IREF profit;

C is the retained profits of the IREF;

D is the purchased IREF profits not previously distributed by the IREF;

E is the amount calculated as the difference between the value of the IREF taxable event and the value of the units as per the balance sheet of the IREF where that amount is less and where the IREF taxable event is as outlined in paragraph (b) of the definition of an IREF taxable event.

(2) “value of the unit in accordance with the balance sheet” means the net asset value of the IREF, as per the balance sheet at the date of the computation of the value of an IREF taxable event, less any amount subscribed for that unit.

Relevant Date: Finance Act 2021