Commentary

B5.127 SPSE—leasing

Business tax
Business tax | Commentary

B5.127 SPSE—leasing

Business tax | Commentary

B5.127 SPSE—leasing

As stated in B5.124 it is likely that the taxation treatment of BP will follow that of SP but HMRC guidance is not available on the matter. This article covers the rules as they are known for SPSE.

The regulations permitted SPSE to be leased but only with sufficient land to frank the payment of SP. For income and corporation tax purposes, the leasing income should have been split between payment for the land (which is taxed as the profits of a property business1) and the payment for the SPSE (which is taxed as income not otherwise charged under

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