BLM72001 | ’Income-into-capital’ schemes and back loaded leases: Relief for set-offs against rentals: avoidance of double taxation - rental excesses

This chapter is concerned with the reliefs for set-off against rentals otherwise taxable of any ‘cumulative accountancy rental excess’ and ‘cumulative normal rental excess’.

Where, for a period of account:

• the accountancy rental earnings exceed the normal rent, there is an “accountancy rental excess”; and

• the normal rent exceeds the accountancy rental earnings, there is a “normal rent excess”.