Introduction: anti-avoidance rules: capital allowances
Chapter 17 of CAA2001 contains a number of anti-avoidance rules that deter exploitation of plant or machinery allowances. They cover
- transactions between connected persons
- transactions where the sole or main benefit is to obtain plant or machinery allowances
- sale and leaseback
- restriction of a lessor’s capital allowances where the assets are used for finance leasing
- sale and finance leaseback
- lease and finance leaseback
- leases where there are arrangements in place the reduce the lessor’s risk from non-payment of rentals by the lessee (known as defeasance)
- sale of assets without the income stream.
Guidance is at CA28000 and CA28900 onwards.