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HMRC internal manual

Business Leasing Manual

HM Revenue & Customs
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Introduction: anti-avoidance rules: asset other than land

CTA10/Ss863-886 / ITA07/Ss681C-681DP (previously ICTA88/S781 - ICTA88/S785) counters arrangements involving the leasing of assets other than land. Such arrangements are, in general, designed to produce

  • a capital receipt to the trader (or an associate), and
  • the allowance to the trader, in the early years of the lease, of relief in respect of an inflated rental.

The legislation may also apply where assets are sold at overvalue followed by a leaseback at an inflated rental

Guidance is at BIM61200 onwards.