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Official guidance
Business Income Manual

BIM61300 · Leasing: avoidance: sale and leaseback of land

  • BIM61301 · Restriction of payments under lease
  • BIM61305 · Definition of commercial rent
  • BIM61310 · Extended meaning of transfer
  • BIM61315 · The calculation of the restriction to the allowable deduction and the carry forward of disallowed amounts
  • BIM61330 · Liability of recipient not affected
  • BIM61335 · New lease after assignment or surrender
  • BIM61340 · Special arrangements
  • BIM61345 · Charge to tax
  1. Measuring the profits (particular trades): contents
  2. Leasing: avoidance: sale and leaseback of land: contents

BIM61300 | Leasing: avoidance: sale and leaseback of land: contents

From HM Revenue & Customs · Business Income Manual

S681A-S681AN Income Tax Act 2007 (ITA 2007), S834-S848 Corporation Tax Act 2010 (CTA 2010)

This section is about legislation which counters certain avoidance devices based on arrangements for the sale and leaseback of land or any interest in land. There are two anti-avoidance rules which:

  • limit the deduction for payments under the lease to a commercial rent, and

  • deal with the situation where a lessee incurs additional rental liability for a comparatively short period in return for the payment of a lump sum.

This chapter contains the following:

Contents8 entries

  1. BIM61301Leasing: avoidance: sale and leaseback of land: restriction of payments under lease
  2. BIM61305Leasing: avoidance: sale and leaseback of land: definition of commercial rent
  3. BIM61310Leasing: avoidance: sale and leaseback of land: extended meaning of transfer
  4. BIM61315Leasing: avoidance: sale and leaseback of land: the calculation of the restriction to the allowable deduction and the carry forward of disallowed amounts
  5. BIM61330Leasing: avoidance: sale and leaseback of land: liability of recipient not affected
  6. BIM61335Leasing: avoidance: sale and leaseback of land: new lease after assignment or surrender
  7. BIM61340Leasing: avoidance: sale and leaseback of land: special arrangements
  8. BIM61345Leasing: avoidance: sale and leaseback of land: charge to tax
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