BLM01020 - Introduction: anti-avoidance rules: sale and leaseback of land

This manual is being updated to reflect FRS 102 (2024 amendments). For guidance on the tax treatment of accounts prepared under IFRS 16 or the revised FRS 102, please refer to pages within the BLM50000 chapter.

CTA10/Ss834-862 / ITA07/Ss681A-681BM (previously ICTA88/S779 and ICTA88/S780) counter certain avoidance devices based on arrangements for the sale and leaseback of land or any interest in land:

  • ICTA88/S779 limits the rent payable to a commercial rent, and
  • ICTA88/S780 deals with the situation where a lessee incurs additional rental liability for a comparatively short period in return for the payment of a lump sum.

Guidance is at BIM61300 onwards.