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Taxation (International and Other Provisions) Act 2010

Overview

943.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.

944.This Chapter corresponds to Chapter 1 of Part 19 of CTA 2010, which makes similar provision for the purposes of corporation tax. It has the following structure.

  • Section 681A summarises the Chapter.

  • Sections 681AA to 681AC say when the Chapter applies and define “relevant income tax relief” and “relevant deduction from earnings”.

  • Section 681AD restricts relevant income tax relief and carries forward relief which has been denied.

  • Sections 681AE to 681AH restrict income tax relief for certain deductions from earnings and carry forward relief which has been denied.

  • Sections 681AI to 681AN are interpretative.

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Explanatory Notes

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