Corporation Tax Act 2010 section 854

New lease treated as ending

Section 854 introduces the rules that treat a new lease as ending in certain circumstances and provides a tie-breaker where more than one ending date could apply.

• Sections 855 to 857 set out specific circumstances in which a new lease is treated as having come to an end for the purposes of this chapter.
• More than one of these provisions may apply in a given situation, potentially producing different deemed ending dates.
• Where conflicting ending dates arise, the new lease is treated as ending on the earliest of those dates.
• This tie-breaker rule applies universally across all possible combinations of the relevant provisions, ensuring a consistent outcome.