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Home / Simons-Taxes /Capital gains tax /Part C2 Computation of chargeable gains /Division C2.12 Leases and capital gains tax /Grant of a lease / C2.1218A Grant of a lease—reverse premiums
Commentary

C2.1218A Grant of a lease—reverse premiums

Capital gains tax

A reverse premium is defined as a payment or benefit by way of inducement where the person receiving the payment becomes entitled to an estate or interest in, or a right in or over, land. It includes payments made or received by a person connected with the grantor or the recipient of the interest1. In other words, a reverse premium is generally paid by a landlord in order to induce a tenant to enter into a lease. Such a payment may take the form of a contribution towards the fitting out costs of the premises.

Tax position of the payer

For capital gains purposes, the landlord might be able to deduct a

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