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The provisions for the set-off of cumulative normal rental excess are intended to ensure that ‘negative depreciation� (being the excess of accountancy rental earnings over normal rent) (see BLM70845) is not recognised for tax (through the taxation of accountancy rental earnings) if at the end of a period of account the balance outstanding to the lessor in respect of a lease is less than the lessor’s original outlay. In other words, ‘negative depreciation� arising in a period is not taxed if the overall balance of depreciation on the lease is positive. And where the overall balance at the end of a period of account is negative, the charge on the negative depreciation arising in a period cannot exceed that overall balance.