Income Tax Act 2007 section 614BQ

Assignments on which neither a gain nor a loss accrues

Section 614BQ deals with what happens when a lessor assigns their interest under a lease in circumstances where no capital gain or loss arises under the "no gain/no loss" provisions, ensuring that cumulative rental excess figures transfer seamlessly to the new lessor.

• Where a lessor assigns their lease interest on a no gain/no loss basis, a deemed period of account ends for the assignor and a new one begins for the assignee at the point of assignment.
• Any cumulative accountancy rental excess and any cumulative normal rental excess that existed for the assignor's period are transferred to become the corresponding figures for the assignee's period.
• If the assignee is a company within the charge to corporation tax on income, the equivalent corporation tax rules in Part 21 of CTA 2010 apply instead of the income tax rules in this Part.
• The "no gain/no loss provisions" take their meaning from the Taxation of Chargeable Gains Act 1992 (section 288(3A)), covering disposals such as transfers between spouses or within groups of companies.