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 Later chargeable amount reduced by more than one ACSI
It is possible that:
	the reduced amount, under section 37(2) of ICTA, of a later chargeable amount is nil, and
	the reduced amount of nil has been calculated by reference to more than one ACSI, but
	the appropriate fraction of each ACSI does not exceed the later chargeable amount.
In these circumstances, section 37(5) of ICTA prevents any relief under section 37(4) of ICTA for the period in respect of which the later chargeable amount arose.
But it is more consistent with the principle behind section 37(5) of ICTA that if the total of the appropriate fractions of the ACSI involved exceeds the later chargeable amount, rent equal to that excess should be treated as paid for the period in respect of which the later chargeable amount arose. Otherwise, that excess will not be available to provide relief under section 37(4) of ICTA. It will be lost, unless it can be used in the calculation of a reduced amount for a different later chargeable amount.
To deal with such a case, section 233(3) uses the test that the “daily amount” of the taxed receipt must exceed the “daily reduction” of the lease premium receipt. Then section 233(6) (by reference to section 230(6)) limits the “daily reduction” of the lease premium receipt to the reduction that is attributable to the taxed receipt in question. The same change was made for income tax in section 293 of ITTOIA (see Change 15(A) in ITTOIA).