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Legislation
Corporation Tax Act 2009

Crossheading Reverse premiums

  • Section 96 Reverse premiums
  • Section 97 Excluded cases
  • Section 98 Tax treatment of reverse premiums
  • Section 99 Arrangements not at arm's length
  • Section 100 Connected persons and property arrangements
  1. Reverse premiums
  2. Reverse premiums

Section 96 | Reverse premiums

From legislation.gov.uk

(1)For the purposes of sections 98 and 99 a payment or other benefit is a reverse premium if—

(a)conditions A, B and C are met, and

(b)it is not excluded by section 97.

(2)Condition A is that a company (“the recipient”) receives the payment or other benefit by way of inducement in connection with a transaction being entered into by—

(a)the recipient, or

(b)a person connected with the recipient.

(3)Condition B is that the transaction (the “property transaction”) is one under which—

(a)the recipient, or

(b)the person connected with the recipient,

becomes entitled to an estate, interest or right in or over land.

(4)Condition C is that the payment or other benefit is paid or provided by—

(a)the person (“the grantor”) by whom the estate, interest or right is granted or was granted at an earlier time,

(b)a person connected with the grantor, or

(c)a nominee of, or a person acting on the directions of, the grantor or a person connected with the grantor.

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