There is provision in ICTA88/S779 (5) for the carry-forward of
disallowed amounts. The instruction at
BIM61250 applies with the substitution
of
the transferor or an associate for
the same person.
Associate is defined in ICTA88/S779 (11).
Arthur sells a property to Brian and leases it back for 20
years.
Rent of £55,000 p.a. is payable for the first 2 years
and £10 p.a. thereafter.
The commercial rent, as defined by ICTA88/S779 (9) is
£7,500 pa.
The rent to be allowed in Arthur's accounts will be:
| Year |
Rent Paid |
Brought Forward |
Total |
Commercial Rent |
Deduction Allowed |
| 1 | £55,000 | 0 | £55,000 | £7,500 | £7,500 |
| 2 | £55,000 | £47,500 | £102,500 | £7,500 | £7,500 |
| 3 - 14 | £120 | £95,000 | £95,120 | £90,000 | £90,000 |
| 15 | £10 | £5,120 | £5,130 | £7,500 | £5,130 |
| 16 - 20 | £50 | 0 | £50 | £30,000 | £50 |