’Income-into-capital’ schemes and back loaded leases: Relief for set-offs against rentals: avoidance of double taxation - rental excesses
This chapter is concerned with the reliefs for set-off against rentals otherwise taxable of any ‘cumulative accountancy rental excess’ and ‘cumulative normal rental excess’.
Where, for a period of account:
- the accountancy rental earnings exceed the normal rent, there is an “accountancy rental excess”; and
- the normal rent exceeds the accountancy rental earnings, there is a “normal rent excess”.