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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 normal rental excess: introduction

The relief for cumulative normal rental excess is also set out in CTA10/S910. It is of much narrower application than the relief for cumulative accountancy rental excess.

Cumulative normal rental excess can only be set off against taxable rents from a lease where periods of account in which accountancy rental earnings exceed normal rent follow periods where normal rent exceeds accountancy rental earnings.

Cumulative normal rental excess unused at the end of a lease cannot be relieved against capital gains disposal proceeds or in any other way.