Landlord Contribution To Extend Floor Space of a Retail Store

Landlord Contribution To Extend Floor Space of...

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I've been reading the Reverse Premium and Landlord Inducement tax guidance but I'm still uncertain whether this relates to this scenario or not.

A landlord has given money to a tenant (company)who was already situated in a property he owned to acquire an existing unit next door and extend their retail store floor space by merging the two together. The works were carried out even though the amount donated by the landlord was far in excess of how much it actually cost to do the work in the end.

There is a debate about whether this falls within the normal rules for a reverse premium. In that the full amount received by the landlord (regardless of the costs) is taxable over the period of the lease. This is suggested under the pretence that the because the tenant is receiving a benefit (i.e. increased floor space) that this is caught by the legislation. However some argue that this only applies when the costs apply to "store fit-out" costs and don't consider the extension of a store (i.e. works to extend the physical property) to fall within the definition of "fit out costs". 

I'm torn between the two, but I'm leaning more towards that the payment would indeed constitute a reverse premium and be taxable over the life of the lease. But I need to find something concrete in the legislation to back this up and I'm struggling to find it for this specific scenario assuming one exists, it may just be a general principle, if so, it would be useful to know which one in particular. 

What do other tax experts think on this matter? Is there any specific information regarding lease or contract details that must be considered?

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