BIM41075 - Receipts: reverse premiums: meaning of ‘payment or other benefit’


The most obvious form of inducement is a cash payment by a landlord to a tenant, but there are many other forms commonly called reverse premiums. A landlord may give a tenant some benefit other than cash, or pay a sum to a third party to meet a liability of the tenant. Not all forms of inducement are taxable reverse premiums.

Broadly, the legislation charges only benefits procured by actually laying out money. It does not catch inducements that represent amounts foregone or deferred by the operator, such as rent-free periods or reduced rents. The smaller deduction for rent payable will reflect such inducements in the tenant's chargeable profits.

Apart from cash payments to the tenant, the commonest forms of inducement that are taxable include:

  • A contribution specified to be towards the tenant's costs, such as start up, fitting out or relocation. There is more about fitting out costs in BIM41085 - BIM41090.
  • Assumption by a landlord of the tenant's liabilities under an existing lease, such as a continuing obligation to pay rent, or the payment of a lump sum to terminate it.
  • Other sums paid to third parties to satisfy some obligation of the tenant.
  • Payment of cash by indirect means, for example writing off a loan that is a liability of the tenant.