Revenue Note for Guidance

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Revenue Note for Guidance

705Q Anti-avoidance provision

(1) Part 25A will not apply to any transaction entered into by or on behalf of a REIT or group REIT or to which it is directly or indirectly a party, unless the transaction is for bona fide commercial reasons and is not for the purpose of avoiding liability to tax.

(2) The reference to REIT or group REIT in subsection (1) includes a reference to a company or a group before it has become or after it has ceased to be a REIT or group REIT and in the case of a group REIT, to a company before it has become or after it has ceased to be a member of the group REIT.

Relevant Date: Finance Act 2021