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HMRC internal manual

Business Leasing Manual

’Income-into-capital’ schemes and back loaded leases: Relief for set-offs against rentals: cumulative accountancy rental excess: interaction with CGT - assignment of lease

TCGA92/S37A is of no application to the assignment of a lease in circumstances where it is treated under the capital gains code as a no gain/no loss disposal. Instead the rules in CTA10/S916 apply (see BLM72130).