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HMRC internal manual

Business Leasing Manual

Plant and machinery leasing - Anti-avoidance: contents


The following guidance provides an overview of the types of tax avoidance encountered within plant and machinery leasing and the legislation designed to combat such transactions.

The guidance is split between traditional lease tax avoidance and tax avoidance of long funding leases, which were introduced on 1 April 2006.

There is a separate section on tax avoidance surrounding the interaction of these rules, in particular where there are lease chains or lease and leasebacks involving both types of lease treatment, and also specific guidance on sales of lease rental streams.