Corporation Tax Act 2009 section 1178A

Major interest in land

Section 1178A defines what constitutes a "major interest in land" for the purposes of qualifying for relief under Part 14 of the Corporation Tax Act 2009, covering freehold ownership and significant leasehold interests across the UK jurisdictions.

  • A major interest in land means either acquiring full freehold ownership or obtaining a qualifying leasehold interest in the property
  • Freehold ownership is defined separately for England and Wales, Scotland, and Northern Ireland to reflect the different land law systems in each jurisdiction
  • A qualifying leasehold interest must be for a minimum term of 7 years, whether obtained by a new grant or by taking over an existing lease
  • Where a lease is acquired by assignment, the unexpired portion of the lease must still have at least 7 years remaining to qualify as a major interest

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