Commentary

C2.1212 Lease derived from a prior lease

Capital gains tax
Capital gains tax | Commentary

C2.1212 Lease derived from a prior lease

Capital gains tax | Commentary

C2.1212 Lease derived from a prior lease

Where a new lease is granted pursuant to an application under the Landlord and Tenant Act 1954, it is likely to be a separate asset from the original lease1. Thus, none of the expenditure in respect of the original lease, assuming that it had not in any case entirely wasted away at the date the new lease was granted, can be taken into account in relation to a disposal of the new lease2.

By concession, no charge to capital gains tax arises in certain circumstances where a lease is extended by means of a surrender of the old lease and the grant of a new, longer lease of the same property to the same lessee3. The concession only applies where:

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