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HMRC internal manual

Business Income Manual

Leasing: Avoidance: Assets other than land: additional capital sum: same interests

S861DD(5)-(7) Income Tax Act 2007, S874(5)-(7) Corporation Tax Act 2010

A tax-relieved payment is not to be taken into account more than once. Where an additional capital sum is obtained in respect of the same interest, for example, on successive assignments, the payments should be compared with the capital sums in the order in which those sums were obtained.