2464.This Chapter is based on section 779 of ICTA. It counters certain avoidance devices based on arrangements for the sale and lease-back of land or on analogous arrangements, such as arrangements for sale of land with reservation of a rentcharge. It restricts tax relief for lease rental expenditure.
2465.The Chapter has the following structure.
Section 834 summarises the Chapter.
Sections 835 to 837 say when the Chapter applies and define “relevant corporation tax relief”.
Section 838 restricts relevant corporation tax relief and carries forward relief which has been denied.
Sections 839 to 842 restrict corporation tax relief for certain insurance company expenses and carry forward relief which has been denied.
Sections 843 to 848 are interpretative.