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.