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HMRC internal manual

Business Leasing Manual

Defining long funding leases: commencement and transition: pre-existing heads of agreement: written agreement

The pre-existing heads of agreement refers to an established commercial consensus that existed as at 20 July 2005 between the two principal parties to the proposed lease. Evidence to show this consensus must exist in writing made on or before 20 July 2005. The written agreement does not have to be as formal as a signed term sheet and could be in the form of letters, emails or more formal documents.

The pre-existing heads of agreement does not have to be binding on either party, nor does it have to be a single document or be signed by lessor and lessee.

You should refer cases of doubt or difficulty to CTISA (CT&BIT) after having obtained the relevant documents.