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HMRC internal manual

Business Leasing Manual

Taxation of lease that are not long funding leases: overseas leasing: monitoring

CTIS (CT&BIT) are monitoring the nature and amount of overseas leasing. Where overseas leasing is disclosed under the Tax Avoidance Disclosure Regulations you should follow the procedures set out for a disclosed scheme.

In addition, if you come across information that suggests

  • a lessor is claiming capital allowances on assets leased to an overseas lessee, and
  • the cost to the lessor exceeds £1m in any 12 month period,

please let CTIS (CT&BIT) have details of

  • the name and tax reference number of the lessor,
  • the accounting period of the lessor,
  • the nature of the asset,
  • the cost of the asset or assets to the lessor,
  • any other information you think may be of interest.

CTIS (CT&BIT) will seek further details from you if necessary.

You should not open an enquiry only to establish whether a lessor is leasing to an overseas lessee. You may, of course, have other reasons to enquire into the transactions or the information may be available for some other reason. Where you do make a report to CTIS (CT&BIT) on the basis of this guidance then, unless the arrangements are disclosed as a potential tax avoidance scheme, or you have any other concerns, there is no need to wait for any comment from CTIS (CT&BIT) before settling any enquires as this report is for information.