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HMRC internal manual

Business Leasing Manual

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HM Revenue & Customs
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’Income-into-capital’ schemes and back loaded leases: Relief for set-offs against rentals: cumulative accountancy rental excess: deeming a period of account to end

CTA10/S915 deems a period of account to end and a new one to begin immediately before the disposal for the purpose of giving relief under TCGA92/S37A (see BLM72050). A further effect of this is to make it clear that any cumulative accountancy rental excess brought forward at the beginning of that period may be set against an excess of normal rent over accountancy rental earnings arising in that period under CTA10/S908, in priority to set-off against the capital gains disposal proceeds under TCGA92/S37A.