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HMRC internal manual

Business Income Manual

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HM Revenue & Customs
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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 is the anti-avoidance legislation that used to be at S779 ICTA 1988.

This chapter contains the following: