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HMRC internal manual

Business Income Manual

Leasing: avoidance: assets other than land: tax-relieved payments

S681DP Income Tax Act 2007, S886 Corporation Tax Act 2010

The capital sums legislation applies where a taxpayer makes a payment for which a deduction is allowed under any of the following tax reliefs.

  • Allowance as a deduction in computing the profits or losses of a trade, profession or vocation.
  • Allowance as a deduction in computing profits or gains chargeable as miscellaneous income, or in computing any loss for which relief is allowable under the miscellaneous income rules.
  • Allowance as a deduction as expenses of management of a company’s investment business (see CTM08000 onwards).
  • Allowance as a deduction as BLAGAB management expenses of an insurance company.
  • Allowance as a deduction from employment income or in computing a loss in an employment.