Hi
UK-REITS and NON UK REITS are vehicles that allows an investor to obtain broadly similar returns from their investment, as they would have, had they invested directly in property.
In the hands of the shareholder, the profits paid out are known as property income distributions ir dividends (PIDs) and are taxable in the same way as profits of a UK property rental business.
Where Non UK REITs are distributed, the profits and foreign tax deducted are declared in the foreign sections under 'income from land and property abroad', where a foreign tax credit can be claimed.
They are not taxed as dividends, but as property income. Foreign tax credit relief is restriced in a similar way to dividends. Article 10 of the UK / USA tax treaty (
Uk/USA Double Taxation Agreement - 2002) limits tax relif to 15% (
DT19852 - Double Taxation Relief Manual: Guidance by country: United States of America: Treaty summary).
Thank you