Introduction Overview Overview Section 838: Relevant corporation tax relief: deduction not to exceed commercial rent
2479.This section restricts relevant corporation tax relief for payments falling within section 835(1) or 836(1) and, in certain cases, provides for such relief to be carried forward. It is based on section 779(1), (2) and (4) to (6) of ICTA.
2480.Subsection (3) puts on a clear statutory footing the practice of spreading lease rental expenditure in accordance with GAAP before applying section 779 of ICTA. This is a minor change in the law, in favour of the taxpayer. See Change 55 in Annex 1.
2481.Section 865 makes the same change in rewriting section 782 of ICTA.