Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Tax cases

19 May 2005
Issue: 4008 / Categories: Tax cases
Abbey National v CCE; R (oao Wilkinson) v CIR; CRC v Jeancharm Ltd; Finance Ltd SpC 466; McEwan SpC 470

Virtual lease

Abbey National owned many leasehold and freehold properties.
It transferred some of the freehold properties to MC Ltd intending to lease back premises that it wished to use. It also assigned its long leasehold interests where the landlord's consent was not required to MC Ltd. With regard to the shorter leases as it would take some time to obtain the landlord's consent in each case and the landlords may be unwilling to consent to the leases being assigned to MC Ltd as it was a new company Abbey National transferred all the economic benefits and burdens of the leases to MC under a virtual assignment.
Abbey National continued to occupy the premises and paid a fee to MC as it would have done in the event of a formal leaseback.
Customs said that the supply by MC to...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon