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HMRC internal manual

Business Leasing Manual

HM Revenue & Customs
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’Income-into-capital’ schemes and back loaded leases: Back loaded leases: normal rent - when it accrues

There is no generally applicable parallel provision in Part 21 of CTA 2010 deeming ‘normal rent’ to accrue evenly over the period of the lease in question falling in a period of account.

In the case of rentals forming part of a lessor’s trading income, CTA09/S52 applies instead, often with the same result.

For the purposes of CTA10/S928 there is no equivalent of paragraph 3(6) (repealed for periods of account beginning on or after 1 April 1998) deeming property income to accrue evenly for the purpose of applying the Condition D (CTA10/S902(7)) which have to be satisfied before a lease comes within Chapter 1 of Part 21 of CTA 2010 (see BLM70561).