Commentary

B6.306 Assignments of short-term leases for profit

Business tax
Business tax | Commentary

B6.306 Assignments of short-term leases for profit

Business tax | Commentary

B6.306 Assignments of short-term leases for profit

A similar set of rules to those described in B6.301 applies if:

  1.  

    (a)     a short-term lease was granted at an undervalue (defined below);

  2.  

    (b)     the lease is assigned; and

  3.  

    (c)     a profit was made on the assignment1.

The person (or company) who assigns the lease (ie not necessarily the original tenant) is treated as entering into a property business transaction—a UK property business if the land to which the lease relates is in the UK or an overseas property business otherwise—and the deemed income (calculated below) is treated as a receipt of the business

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