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HMRC internal manual

Business Leasing Manual

From
HM Revenue & Customs
Updated
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’Income-into-capital’ schemes and back loaded leases: Lease changes: catching-up charge - consequences

The amount of the catching-up charge represents cumulative accountancy rental excess to be carried forward from the deemed period of account in which the charge under CTA10/S923 crystallises. That excess is treated in the same way as ordinary cumulative accountancy rental excesses arising for the (deemed) period of accounting beginning immediately after the period of the charge and subsequently.