03 August 2006
The taxation of a premium payable under a short lease is dealt with in ITTOIA 2005, Chapter 4. Section 279 deals with a sum payable 'instead of the whole or part of the rent for a period', but as far as I can see, there is no definition of a premium for the purposes of s 277. Suppose a potential tenant offers to pay a (10%) discounted rent of £21,600 in advance, rather than, say, £1,000 per month, for a two-year tenancy.
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