Commentary

B5.250 Land sold with right to repurchase—restriction of relief

Business tax
Business tax | Commentary

B5.250 Land sold with right to repurchase—restriction of relief

Business tax | Commentary

Land sold with right to repurchase

B5.250 Land sold with right to repurchase—restriction of relief

Where a property income charge arises under CTA 2010, s 224 and ITTOIA 2005, s 284 in respect of a sale of land with right to repurchase, no relief is available under CTA 2010, ss 227, 287 or ITTOIA 2005, ss 60, 62, see B6.309. This is an anti-avoidance measure to counter schemes under which land is sold with a provision for it to be reconveyed at a reduced price, the object being to produce large sums qualifying for the reliefs

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