Annex 1: Minor Changes in the Law Change 13: Trading and property income: lease premiums etc: restrictions on expenses under sections 63 and 232 in respect of taxed receipt: sections 66, 67, 233 and 234 Overlap in periods for which more than one later chargeable amount is reduced by one ACSI
It is also possible that the reduced amount of more than one later chargeable amount has been calculated under section 37(2) of ICTA by reference to an ACSI and that the amount of each of the later chargeable amounts has been reduced to nil. In these circumstances, section 37(4) and (5) of ICTA work satisfactorily if there is no overlap between the periods in respect of which each of the later chargeable amounts arose. But it is not at all clear how section 37(4) and (5) of ICTA are intended to operate if there is such an overlap.
If there is an overlap between the periods in respect of which each of the later chargeable amounts arose, it is reasonable that section 37(5) of ICTA should apply so that the total of the reductions in all later chargeable amounts by reference to the ACSI should be taken into account in determining how much, if any, rent should be treated as paid under section 37(4) of ICTA.
To deal with such a case, section 233(2) and (5) make explicit provision if there is an overlap in the periods for which more than one lease premium receipt is reduced under section 228 or under section 288 of ITTOIA by reference to a taxed receipt. The same change was made for income tax in section 293 of ITTOIA (see Change 15(A) in ITTOIA).
Without these changes, section 233 would produce the same result as section 37(5) of ICTA if there is one taxed receipt and one lease premium receipt. These changes make section 233 work if:
	a lease premium receipt is reduced by reference to more than one taxed receipt; or
	a taxed receipt reduces more than one lease premium receipt and there is an overlap in the periods in relation to which those lease premium receipts arise.
Section 66(2), (5) and (6) is based on that part of section 87(5) of ICTA that applies section 37(5) of ICTA. It includes similar changes to those in section 233. The same change was made for income tax in section 64 of ITTOIA (see Change 15(A) in ITTOIA).