»Ê¹ÚÌåÓýapp

A share dividend is said to be ‘strippedâ€� when the owner of the share sells or transfers the right to receive one or more distributions payable in respect of the share, without selling or transferring the share. »Ê¹ÚÌåÓýapp tax treatment of the buyer of a strip is dealt with below. For the tax treatment of the seller, see IFM28240.

Deduction of tax from stripped PID

Where a property income distribution paid by a UK-REIT is stripped, the UK-REIT is obliged to deduct tax on payment, regardless of the nature of the recipient (SI2006/2867/reg7(7)).

Tax treatment of buyer of PID

»Ê¹ÚÌåÓýappre are no special rules for strips of PID and the normal rules for the taxation of PID apply to PID received by the buyer of PID strips. (see SAIM5300 onwards).

»Ê¹ÚÌåÓýapp PID will in general be profits of a property business in the buyer’s hands. »Ê¹ÚÌåÓýapp exceptions are for PID received in the course of trade carried on by a dealer in shares or a member of Lloyd’s when the trading provisions of CTA 2009 have priority. »Ê¹ÚÌåÓýappse are taxable as trading income of the buyer. »Ê¹ÚÌåÓýapp cost of the strip will be an expense of the trade.

»Ê¹ÚÌåÓýapp recipient of the PID will be able to offset the tax deducted from the PID on payment against their UK tax, claim repayment if they have no net liability to tax or (for non-residents) may be able to claim relief under the dividend article of the relevant double tax treaty.