CA33020 - IBA: relevant interest: creation of subordinate interest
Budget 2007 announced a business tax reform package including the gradual withdrawal of IBAs and ABAs over four years. Legislation was introduced in FA08 to give effect to those changes. »Ê¹ÚÌåÓýapp phased withdrawal of IBA writing down allowances had effect for chargeable periods ending on or after 1 April 2008 for businesses within the charge to CT and 6 April 2008 for businesses within the charge to IT. »Ê¹ÚÌåÓýappre are no IBA writing down allowances for the financial year beginning on 1 April 2011 and subsequent years.
CAA01/S288
An interest that is the relevant interest stays the relevant interest if a subordinate interest is granted out of it unless a long lease is granted out of the relevant interest and an election is made to treat that grant of a long lease as the sale of the relevant interest CA33100, (Woods v R M Mallen Engineering Ltd. 45TC619). In the Woods v Mallen case, a sublease was created out of a 99-year leasehold interest that was the relevant interest in a building. »Ê¹ÚÌåÓýapp sublease expired three days before the leasehold interest. A claim that the sublease was the relevant interest was refused.