REIT

REIT and Dividend Information

Real Estate Investment Trusts (REITS)

Following the admission to the Channel Islands Securities Exchange Authority (formerly the Channel Islands Stock Exchange) and the completion of the acquisition of the portfolio of assets from Braemar Group PCC Limited, Ground Rents Income Fund plc converted to a Real Estate Investment Trust (REIT) with effect from 15 August 2012.

REITs are quoted property corporate entities which are not liable to corporation tax on their rental income or capital gains arising from their property rental business.

In order to receive this tax treatment a REIT has to meet certain conditions. One of these is to distribute 90% of its property rental income (being gross rental income after deducting certain allowable expenses) as a Property Income Distribution (PID).

Profits distributed as PIDs are potentially fully taxable in shareholders’ hands as income arising from a property business. PIDs are normally paid out after deduction of basic rate tax at source, which the REIT pays to HMRC on behalf of the shareholder.

However, certain categories of shareholder are entitled to receive PIDs without suffering a tax deduction at source. These are mainly UK resident companies, UK public bodies, UK charities, UK pension funds and managers of ISAs, PEPs and Child Trust Funds.

If you qualify to receive your PID without deduction of withholding tax, you should complete one of the attached forms depending on whether or not you are the beneficial owner of your shareholding or an intermediary. Please read the notes on both forms carefully before completion, particularly Note 1 concerning the 2 ISINs covered by the Company REIT status.  The completed form should be sent to the company’s registrars:

Capita Registrars
The Registry
34 Beckenham Road
Beckenham
Kent BR3 4TU

Most shareholders, including all individuals and all non-UK residents, do not qualify for gross payment and should not complete the forms. Non-UK resident shareholders are not able to apply for an exemption to receive their income gross and any recoverability of the withholding tax will be based on the terms of any double taxation treaty that may be in force between the UK and the country in question.

Other dividends paid by REITs out of non-property rental activities are treated as ordinary dividends and are not subject to withholding tax.

Shareholders who are in any doubt about their tax position, or who are subject to tax in a jurisdiction other than the United Kingdom, should consult their own appropriate independent professional adviser, particularly concerning their tax liabilities on PIDs to determine whether they are entitled to claim any repayment of tax, and, if so, the procedure for so doing.

For more detailed information please refer to Part 9 of the company’s Listing Document.

Ground Rents Income Fund plc Incorporated in England and Wales Company No.8041022. Registered Office: 72 Welbeck Street, London W1G 0AY                                                                  Email: info@groundrentsincomefund.com