CORPORATION TAX – Property holding company part of a larger group of companies letting its properties to the trading company of the same group – Assignment by the property company to a bank of the right to receive its rents for a five year period in consideration of a lump sum payment received from the bank – Whether the lump sum is to be treated and taxed as an income receipt or as a capital receipt – Whether the assignment of the rents by the property holding company was a part disposal of its properties or an entire disposal of five years’ rents – Whether roll over relief is available to the property holding company – Sections 15 and 18 Income and Corporation Taxes Act 1988; sections 21, 42, 152 and 155 Taxation of Chargeable Gains Act 1992 – Appeal allowed
[2000] UKSC SPC00255
Bailii
England and Wales
Updated: 29 September 2021; Ref: scu.195358 br>