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HMRC internal manual

Business Leasing Manual

HM Revenue & Customs
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’Income-into-capital’ schemes and back loaded leases: Relief for set-offs against rentals: simultaneous disposals

TCGA92/S37A(1) provides a rule for allocating deductions for cumulative accountancy rental excess where, exceptionally, disposals qualifying for relief under TCGA92/S37A(3) occur simultaneously (for example a disposal of the asset itself and a disposal of the shares in the lessor company). The rule is that the cumulative accountancy rental excess should be apportioned on a just and reasonable basis.