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Lease surrender premium received

Tax treatment for lease surrender premium received by client, outside of the lease agreement

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I am hoping someone may have come across this question or scenario too. A client (limited partnership) has received an early lease termination premium on UK properties. I asked the client if the amount received was as per lease agreement i.e. a computation method or an amount was stated within the lease, and he has come back saying it was all outside of the lease agreement.

The partnership and the partners are non uk resident. Partners until 19/20 completed SA700 (Non-UK resident landlord tax return). However, as per 20/21 all has been moved to corporation tax.

My question is that due to this move to CT does all of this lease termination premium recieved less related expenses now becomes taxable under CT. Whereas before under SA700 may have had to split between income tax and capital gains depending if within the lease terms or not etc. Now under CT I don't need to worry if within the lease term or outside, and all is income under CT, and all will be taxable under UK tax.

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