In British Eventing Ltd [2011] TC 00664, BEL assigned its lease of Tweseldown Racecourse (‘the Racecourse’) to Tweseldown Equisport Ltd (TEL). A month before this it, began the process of opting to tax the land and buildings. BEL required HMRC’s permission to opt to tax the Racecourse, because before the assignment BEL had let the racecourse and the rents were exempt. This was not a situation where HMRC’s permission is granted automatically.

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