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HMRC internal manual

Business Leasing Manual

Introduction: anti-avoidance rules: back-loaded leases and 'income into capital' schemes

Part 21 CTA10 / Part 11A ITA07 counters two types of scheme:

  • back-loaded leases designed to defer taxation of income, and
  • ‘income-into-capital’ schemes designed to turn taxable income into (effectively untaxed) capital receipts.

Guidance is in this manual at BLM70000 onwards.