Part 19Sale and lease-back etc

Chapter 2New lease of land after assignment or surrender

Taxation of consideration

852Position where new lease does not include all original property

1

This section applies for the purposes of section 851 if the property which is the subject of the new lease does not include all the property which was the subject of the original lease.

2

The consideration received by L must be treated as reduced to the portion of it found under subsection (3).

3

The portion is that which is reasonably attributable to such part of the original property as—

a

consists of the property which is the subject of the new lease, or

b

is included in the property which is the subject of the new lease.

4

The original property is the property which was the subject of the original lease.