BIM61300 - Leasing: avoidance: sale and leaseback of land: contents

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.

This chapter contains the following:

Guidance on:

• The commercial background and accountancy treatment of leasing is at BIM61000 onwards.
• Anti-avoidance legislation in ICTA88/S781 - ICTA88/S785 (leased assets other than land) is at BIM61200 onwards.
• Anti-avoidance legislation in FA97/SCH12 (back-loaded leases and ‘income-into-capital’ schemes) is in the Finance Leasing Manual at FLM27.01 onwards.
• Income from property (Schedule A) is in the Property Income Manual (PIM).