Corporation Tax Act 2009 section 97

Excluded cases

Section 97 sets out the circumstances in which a payment or benefit received in connection with a property transaction will not be treated as a reverse premium and therefore will not be subject to the reverse premium tax charge.

• A payment or benefit is not a reverse premium to the extent it has already been used to reduce expenditure qualifying for capital allowances under the general rule excluding contributions
• A payment or benefit is not a reverse premium if the transaction is entered into by an individual and relates to premises occupied, or to be occupied, as that individual's only or main residence
• A payment or benefit is not a reverse premium to the extent it represents consideration for the transfer of a property interest that constitutes the sale in a sale and leaseback arrangement
• A sale and leaseback arrangement is defined by reference to specific provisions in the Income Tax Act 2007 and the Corporation Tax Act 2010 dealing with payments connected with transferred land