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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Specific deductions: premiums: artificial leasing transactions

S303 Income Tax (Trading and Other Income) Act 2005, S243 Corporation Tax Act 2009

The aim of these rules is to prevent artificial manipulation of the duration of a lease. The effect is, broadly, to ensure that a lease is treated as ending on the earliest date when it is expected to end to avoid short leases being presented as long leases. See PIM1206 for further details.