The Rent Factoring legislation was introduced to address avoidance involving the disposal of rental streams. In some circumstances the ‘consideration’ received on the disposal of a rental stream was not taxable, or the transaction was structured so that the sum was not brought into charge as income (e.g. a capital sum). Where the sum was capital it could effectively escape taxation, either because of costs that could reduce the gain significantly, or because of the availability of capital losses.

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