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HMRC internal manual

Business Leasing Manual

HM Revenue & Customs
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‘Income-into-capital’ schemes and back loaded leases: Introduction to back-loaded leases: pre-FA97/Sch 12

The reasons for avoidance or deferral of tax being possible pre-FA97/Sch 12 differed depending on whether the lessor’s earnings were taxable as property income or as trading income. But common to both situations was that the lessor was reporting higher earnings in its commercial accounts than it contended should be taxed, so enhancing the timing gains produced by the tax consequences.