[CFM97630] CFM97630 – Interest restriction: charities: companies with exempt property income
This guidance is relevant to companies that receive property income to which a charitable exemption applies and to worldwide groups containing such companies.
It is also relevant to entities such as housing associations that may take a variety of legal forms, including industrial co-operatives, provident societies, companies or trusts. Except in the case of trusts, they will normally be within the ambit of corporation tax. See CTM40400+
Where such income would otherwise be taken into account as property income, the analysis of the application of the CIR is different from that where a company has charitable trade profits CFM97620.