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.