Corporation Tax Act 2010 section 852

Position where new lease does not include all original property

Section 852 explains how the taxable consideration is adjusted when a new lease covers only part of the property that was included in the original lease.

• This section applies where the new lease does not cover all of the property that was subject to the original lease.
• The consideration received by the landlord (L) is reduced to only the portion reasonably attributable to the property now included in the new lease.
• The relevant portion is the amount that can reasonably be linked to the part of the original property that either forms or is included in the new lease.
• The original property means the property that was subject to the original lease before the assignment or surrender took place.