BIM61300 - Leasing: avoidance: sale and leaseback of land: contents
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:
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BIM61301Restriction of payments under lease
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BIM61305Definition of commercial rent
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BIM61310Extended meaning of transfer
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BIM61315Calculation of tax deduction
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BIM61330Liability of recipient not affected
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BIM61335New lease after assignment or surrender
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BIM61340Special arrangements
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BIM61345Charge to tax