Income Tax (Trading and Other Income) Act 2005 section 100

Excluded cases

Section 100 identifies three situations where a payment or benefit that would otherwise be a reverse premium is excluded from the reverse premium tax charge.

• Payments or benefits already accounted for as reductions to capital allowances qualifying expenditure are not treated as reverse premiums.
• Payments or benefits received by an individual in connection with a property transaction relating to their only or main residence are excluded.
• Payments or benefits that form the consideration for a transfer of a land interest constituting the sale element of a sale and lease-back arrangement are excluded.
• A sale and lease-back arrangement is defined by reference to specific provisions in the Income Tax Act 2007 and the Corporation Tax Act 2010.