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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. Tax treatment of reverse premiums

Section 98 | Tax treatment of reverse premiums

From legislation.gov.uk

(1)A reverse premium is treated for corporation tax purposes as a receipt of a revenue nature.

(2)If the recipient enters into the property transaction for the purposes of a trade carried on (or to be carried on) by the recipient, the reverse premium is brought into account in calculating the profits of the trade.

(3)If subsection (2) does not apply, the reverse premium is charged to corporation tax in accordance with section 250 (reverse premium taxed as property business receipt).

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