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HMRC internal manual

Business Income Manual

Specific receipts: reverse premiums: contributions to fitting out costs on assets qualifying for capital allowances

S100(1) Income Tax (Trading and Other Income) Act 2005, S97(1) Corporation Tax Act 2009

If the landlord contributes to the tenant’s expenditure on fitting out, the contribution may be deducted from expenditure otherwise qualifying for capital allowances in the tenant’s hands under S532 Capital Allowances Act 2001. See CA14100.

Any sum is not a reverse premium to the extent that it reduces the recipient’s capital allowances qualifying expenditure in this way.