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HMRC internal manual

Business Leasing Manual

HM Revenue & Customs
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Introduction: anti-avoidance rules: sale and leaseback of land

CTA10/Ss834-862 / ITA07/Ss681A-681BM (previously ICTA88/S779 and ICTA88/S780) counter certain avoidance devices based on arrangements for the sale and leaseback of land or any interest in land:

  • ICTA88/S779 limits the rent payable to a commercial rent, and
  • ICTA88/S780 deals with the situation where a lessee incurs additional rental liability for a comparatively short period in return for the payment of a lump sum.

Guidance is at BIM61300 onwards.