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Contents

Official guidance
Business Income Manual

BIM41050 · Specific receipts: reverse premiums

  • BIM41051 · Meaning of ‘reverse premium’ and terms used in connection with reverse premiums
  • BIM41052 · Receipts: reverse premiums: the commercial background
  • BIM41055 · The legislation
  • BIM41060 · Tax treatment of the payer
  • BIM41075 · Meaning of ‘payment or other benefit’
  • BIM41085 · Fitting out costs
  • BIM41090 · Contributions to fitting out costs on assets qualifying for capital allowances
  • BIM41105 · Conveyance of a freehold
  • BIM41110 · Assignment of a lease
  • BIM41125 · Timing of the receipt - the normal case
  • BIM41130 · Timing of the receipt: the avoidance case: how to recognise it
  • BIM41135 · Timing of the receipt: timing in the avoidance case
  • BIM41140 · Specific exclusions
  1. Specific receipts: reverse premiums: contents
  2. Specific receipts: reverse premiums: conveyance of a freehold

BIM41105 | Specific receipts: reverse premiums: conveyance of a freehold

From HM Revenue & Customs · Business Income Manual

An inducement to buy a freehold interest is not a reverse premium.

Although a person buying a freehold becomes entitled to an estate or interest in land, the inducement is not a reverse premium because of the requirement for the payment or benefit to be paid by the person by whom the estate, interest or right is granted (or by a connected person or nominee, etc). A lease or other lesser interest in land is granted because it is created out of a superior interest in that land which the grantor holds. A freehold, however, is the highest interest in land that may be held. It cannot be granted.

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