Corporation Tax Act 2010 Explanatory Notes

Overview

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.

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