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HMRC internal manual

Capital Gains Manual

Leases: property income: non-arm's length grant of lease: deemed premium


  • the grant of a short lease is not at arm’s length;
  • a premium is paid, but it is less than would have been paid if the lease had been granted at arm’s length; and
  • a further premium is deemed to have been paid, see CG70825,

only the amount of the actual premium will be taken into account in determining the amount chargeable as income, see CG70900.