BLM72005 - Schedule 12 FA 1997:
relief for set-offs against rentals: avoidance of double taxation -
function of the rental excess reliefs
The function of the two reliefs in the scheme of FA97/Sch12
is different:
- The relief for cumulative accountancy
rental excess is intended to ensure that there is no double
taxation of the lessor's return from the lease (see
BLM72015).
- The relief for cumulative normal rental
excess is of much narrower application. Its purpose is merely to
ensure that negative depreciation for a period is not taxed under
the Schedule (as part of 'accountancy rental earnings') to the
extent that it can be franked by accumulated positive depreciation
from earlier periods (see
BLM72110).
