Commentary

B6.310 Deductions available in respect of deemed income

Business tax
Business tax | Commentary

B6.310 Deductions available in respect of deemed income

Business tax | Commentary

B6.310 Deductions available in respect of deemed income

The rules in B6.301–B6.309 explain how capital receipts can be taxed as income. In such circumstances, the payer of such amounts can qualify for relief as if the capital payments (or the proportion taxed as income) were revenue expenses.

Where the land is used in connection with a trade the relief is given under ITTOIA 2005, ss 60–67 or CTA 2009, ss 62–67 (see B2.447) as a trading deduction. Where the tenant is occupying the land for the purpose of carrying on a property business or the tenant has sublet the land, the deduction is given as an expense of the property business1. The availability of any relief is subject to the normal rules that can prevent relief (for example, the land not being used wholly or exclusively for the purposes of the property business)2. For leases granted on or

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