Corporation Tax Act 2010 section 873

Sum obtained

Section 873 sets out four alternative conditions (B, C, D and E) under which the lease-related payment rules in this Chapter may apply, each involving a company within the charge to corporation tax obtaining a capital sum connected with an interest in a lease or the underlying asset.

• Condition B applies where the person making the payment obtains a capital sum in respect of the lessee's interest in the lease, and that person is a company within the charge to corporation tax.
• Condition C applies where an associate of the person making the payment obtains a capital sum as consideration for the lessee's interest in the lease, and that associate is a company within the charge to corporation tax.
• Condition D applies where an associate of the person making the payment holds the lessor's interest in the lease (or any other interest in the asset), that associate obtains a capital sum in respect of that interest, and the associate is a company within the charge to corporation tax.
• Condition E applies where an associate of the person making the payment holds the lessor's interest in the lease (or any other interest in the asset), and a further associate of that associate obtains a capital sum as consideration for the interest, with that further associate being a company within the charge to corporation tax.