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HMRC internal manual

Property Income Manual

Deductions: specific items: sale and leaseback of land

ICTA88/S779 and ICTA88/S780 counter certain avoidance devices based on arrangements for the sale and leaseback of land or any interest in land.

  • ICTA88/S779 limits the rent payable to a commercial rent, and
  • ICTA88/S780 deals with the situation where a lessee incurs additional rental liability for a comparatively short period in return for the payment of a lump sum.

For detailed instructions see BIM61300 onwards.