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:
| BIM61301 | Leasing: avoidance: sale and leaseback of land: ICTA88/S779 |
| BIM61305 | Leasing: avoidance: sale and leaseback of land: definition of commercial rent |
| BIM61310 | Leasing: avoidance: sale and leaseback of land: extended meaning of transfer |
| BIM61315 | Leasing: avoidance: sale and leaseback of land: carry-forward of disallowed amounts |
| BIM61320 | Leasing: avoidance: sale and leaseback of land: rent in advance for more than year |
| BIM61325 | Leasing: avoidance: sale and leaseback of land: definitions |
| BIM61330 | Leasing: avoidance: sale and leaseback of land: liability of recipient not affected |
| BIM61335 | Leasing: avoidance: sale and leaseback of land: ICTA88/S780 |
| BIM61340 | Leasing: avoidance: sale and leaseback of land: special arrangements |
| BIM61345 | Leasing: avoidance: sale and leaseback of land: assessment |
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).
