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HMRC internal manual

Business Leasing Manual

’Income-into-capital’ schemes and back loaded leases: Lease changes: calculation of catching-up charge

The catching-up charge under CTA10/S923 is imposed on the ‘cumulative accountancy rental excess’ (see BLM73010) which would have been in existence immediately prior to the time when the lease first comes within Chapter 2 of Part 21 of CTA 2010 if Chapter 2 had applied to the lease for all periods beginning with 26 November 1996. This is the income which may be turned into capital.

The cumulative accountancy rental excess is the difference between:

  • the rental income recognised in the accounts from 26 November 1996 to the time the lease first comes within Chapter 2, and
  • the income actually recognised for tax over that period.