Chancery Division.

[The appeal against this decision is reported at [2003] BTC 127.]

Lightman J.

Judgment delivered 13 June 2001.

Corporation tax – Rent factoring scheme – Assignment of future rent in return for discounted lump sum – Whether rental assignment effected transfer of interest in land – Whether lump sum income or capital receipt – Whether assignment was part disposal of properties – Whether roll over relief available – Conveyancing Act 1881, s. 10 – Law of Property Act 1925, s. 141, 205 – Income and Corporation Taxes Act 1988, s. 15, 18 – Taxation of Chargeable Gains Act 1992, s. 21.

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