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HMRC internal manual

Business Leasing Manual

’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”.