SCHEDULES

SCHEDULE 6U.K. Tax treatment of receipts by way of reverse premium

Exclusion of consideration under sale and lease-back arrangementU.K.

7U.K.This Schedule does not apply to a payment or benefit to the extent that it is consideration for the transfer of an estate or interest in land which constitutes the sale in a sale and lease-back arrangement.

A “sale and lease-back arrangement” means any such arrangement as is described in section 779(1) or (2) or section 780(1) of the Taxes Act 1988.