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HMRC internal manual

Business Leasing Manual

’Income-into-capital’ schemes and back loaded leases: Relief for set-offs against rentals: CGT disposal not of asset outright

TCGA92/S37A also makes provision for the deduction of cumulative accountancy rental earnings from capital gains disposal proceeds in less straightforward circumstances than the outright disposal of the leased asset by the lessor. Those circumstances are:

  • part disposals of the leased asset (see BLM72075);
  • disposals (or part disposals) of an asset ‘representing’ the leased asset (see BLM72080).