BIM41050 - Receipts: reverse premiums: contents and introduction


This guidance listed below is primarily concerned with reverse premiums receivable on or after 9 March 1999. The tax treatment of these premiums is determined by legislation in

  • FA99/S54 and FA99/SCH6 for CT cases (and IT cases up to 2004-05)
  • ITTOIA05/S99 to S103 or ITTOIA05/S311 for IT cases for 2005-06 onwards.

Guidance on premiums receivable before 9 March 1999 is in BIM41145.

Terms used in connection with reverse premiums

A landlord is a person who grants a lease, and may also be known as a lessor.

A tenant is a person who takes a lease, and may also be known as a lessee.

A lease is granted when the owner of an interest in land gives someone else the right to occupy it for a fixed term. When the term comes to an end, the right granted reverts to the landlord. As long as the lease continues, the landlord's rights are called the reversion, or the reversionary interest.

A lease is assigned when an existing tenant disposes of his right to occupy for the remaining term of the lease to a new tenant.

BIM41051The commercial background
BIM41055Overview of the legislation
BIM41060Tax treatment of the payer
BIM41065Commencement
BIM41070Meaning of ‘reverse premium’
BIM41075Meaning of ‘payment or other benefit’
BIM41080Inducements which are not ‘reverse premiums’
BIM41085Fitting out costs
BIM41090Contributions to fitting out costs on assets qualifying for capital allowances
BIM41095Meaning of a ‘relevant transaction’ and ‘property transaction’
BIM41100Person providing the inducement
BIM41105Conveyance of a freehold
BIM41110Assignment of a lease
BIM41115Person chargeable
BIM41120Type of income
BIM41125Timing of the charge: the normal case
BIM41130Timing of the charge: the avoidance case: how to recognise it
BIM41135Timing of the charge: the avoidance case: when to impose the charge
BIM41140Specific exclusions not chargeable
BIM41145Receivable before 9 March 1999