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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Leases: Sch.A: non-arm's length grant of lease: imputed premium


  • the grant of a short lease is not at arm’s length;
  • no premium is actually paid; and
  • a premium is deemed to have been paid, see CG70825,

none of that deemed premium will be chargeable to tax under Schedule A and the whole of the deemed premium will be brought into the computation of the gain arising on the grant of the lease.