Property income ringfenced but other taxable
income subject to corporation tax at 20%.
Point of taxation moves from fund to investor.
Distributions paid in three types: property, interest and dividends. Property
income is paid net of 20% tax (unless in ISA/pension) which non taxpayers can
reclaim. Dividends and interest paid gross.
At least 60% of PAIFs net income must be from exempt
property investment business. Value in property
investment must be at least 60% of total assets.