BLM74625 - 鈥橧ncome-into-capital鈥� schemes and back loaded leases: Back loaded leases: alteration of lease granted before 26 November 1996
Where a lease granted prior to 26 November 1996 is said to have been revised subsequently so that 鈥榥egative depreciation鈥� (the excess of accountancy rental earnings over normal rent) arises for the first time, you should consider whether the revision is so extensive as to amount to a new lease of the asset. You should report attempts to revise leases in this way to take advantage of the grand-fathering of existing leases to CS&TD.