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1 Hotel cover.indd - Nicola Cottam

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● Residual (non-property investment) business continues to be taxed at 30%, and must represent less than 25%<br />

of the REITs total profits and less than 25% of the REITs gross assets (the balance of business test).<br />

● Generally, shareholders are taxed at 22% on distributions, to mirror direct property ownership.<br />

● One-off entry charge of 2% of the market value of properties being transferred into the tax-exempt business.<br />

● Sale of property from the tax-exempt business of a REIT is exempt from capital gains tax.<br />

● Owner-occupied property is excluded from the tax-exempt business.<br />

Initial Impact<br />

Initially, nine UK property companies converted to REITs from 1 January 2007 and a handful of other companies<br />

have either confirmed they will convert or intend to convert during 2007.<br />

At present, however, UK hotel groups have been put off from conversion. The key issue appears to be the restriction<br />

on owner/occupiers converting to REITs. Additionally, even if the restriction on owner-occupied property<br />

was lifted such that it could form part of the tax exempt property rental business, hotel owner/operators may still<br />

struggle to satisfy the 75%/25% balance of business test. It seems that currently the only way for hotel operators<br />

to convert to REITs in the UK would be to separate the assets from the running of the hotel.<br />

What does the future hold for UK REITs?<br />

Many analysts are excited by the growth potential for UK REITs.<br />

Worldwide, 2006 was a great year for the REITs market. In the US, REIT prices have been boosted by a number of<br />

large privatisations and outpaced the broader domestic markets for a seventh year in a row based on S&P figures.<br />

The market in Asia continued to grow, whilst in Europe the introduction of REITs in the UK and Germany in<br />

2007, with Italy to follow in 2008, has created a positive environment in the sector.<br />

The launch of UK REITs is expected to lead to a surge of interest in the property market as REITs become as popular<br />

an investment asset as equities and bonds. However, fund managers Fidelity International are more cautious in<br />

their outlook and predict that it could take up to 30 years for the UK REIT market to mature and diversify based<br />

on the evidence of countries like the US and Australia.<br />

More to come<br />

Key Issues: Real Estate Investment Trusts: An Overview<br />

After the introduction of the UK REIT rules, making the split between operators and property owners continues to<br />

be a logical and cost-effective decision – enabling both groups to focus on what they do best. The lodging industry,<br />

once considered less attractive than other types of commercial property, has seen record levels of activity from<br />

investors looking to buy hotel properties.<br />

March 2007 <strong>Hotel</strong> Report Guide to UK <strong>Hotel</strong>s l © William Reed Publishing 34

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