Commentary

B5.231 Where freehold retained

Business tax
Business tax | Commentary

B5.231 Where freehold retained

Business tax | Commentary

B5.231 Where freehold retained

The question arose in England in Hughes v Utting (BG) & Co Ltd1. The company built houses and disposed of them by granting 99-year leases at premiums and yearly ground rents. The company contended that in computing its profits for tax purposes nothing ought to be included in respect of the premiums or of the ground rents; and, alternatively, that as regards the ground rents no profit arose in respect of the value of the reversionary interest in the house, or of the value of the ground rents until the ground rents were sold. The Special

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