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HMRC internal manual

Business Leasing Manual

’Income-into-capital’ schemes and back loaded leases: Back loaded leases: first condition - lease of real property

In the case of a lease of real property where a contract or agreement for the lease is followed later by ‘completion’ the lease will have been ‘granted’ on the later date. In other cases, including real property cases where the agreement for a lease is not followed by ‘completion’, the lease will have been granted when the contract or agreement is made.