The REIT Framework

The Real Estate Investment Trust (“REIT”) framework was initially introduced and regulated in Italy by the 2007 budget law. The framework was subsequently integrated and modified in November 2014.

The regime offers the possibility of adopting, in the presence of certain requirements set by the law, a taxation system in which the profit deriving from the property leasing business and the profit from the disposal of properties are exempt from taxation (so-called “exempt activity”). For the current year COIMA RES falls under this particular regime and is therefore it is not required to pay taxes on the Italian territory.

The main requirements and obligations of the special tax regime guaranteed to REITs can be summarized as follows:


  • Company incorporated in the form of a joint stock company
  • Residence in the territory of the Italian state or in an EU state
  • The shares are traded on regulated markets


  • Investment rules
  • Limits on the concentration of risks on investments and counterparties
  • Maximum leverage limit, at individual and group level


  • No shareholder must have more than 60% of the voting rights
  • Free float greater than 25%


  • The properties owned represent at least 80% of the total assets
  • Revenues from leasing of owned properties represent at least 80% of total revenues


  • Obligation to distribute at least 70% of the net profit (determined as per the separate accounts) deriving from the leasing activity and from equity investments
  • Obligation to distribute, within 2 years following the realisation, of 50% of the capital gains realised on disposal of properties and of investments in SIIQ, SIINQ and qualified real estate funds