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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Leasing: avoidance: sale and leaseback of land: extended meaning of transfer

S681AA, S681AB Income Tax Act 2007, S835, S836 Corporation Tax Act 2010

References to the transfer of an estate or interest in land include references to:

  • the granting of a lease or any other transaction involving the creation of a new estate or interest in the land,
  • the transfer of a lessee’s interest under a lease by surrender or forfeiture,
  • any transaction or series of transactions affecting land such that some person is the owner or one of the owners both before and after the transactions but another person becomes or ceases to be one of the owners.