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HMRC internal manual

Business Leasing Manual

‘Income-into-capital’ schemes and back loaded leases: contents

FA97/Schedule 12 was introduced to counter two categories of tax avoidance using leasing:

  • Back end loaded leases, and
  • Income into capital schemes

The legislation has had a number of modifications since introduction and can now be found, following tax law re-write, at Part 21 CTA 2010 for Corporation Tax purposes and Part 11A ITA 2007 for Income Tax purposes.

Much of the following guidance was originally in the Finance Leasing Manual (now no longer available). In that form the guidance was issued after extensive consultation with representative bodies. The guidance that follows is based upon material updated for legislative changes and amended for clarification.