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HMRC internal manual

Business Leasing Manual

‘Income-into-capital’ schemes and back loaded leases: Definition of a Chapter 2 of Part 21 of CTA 2010: Condition A: deemed different treatment in group consolidated accounts

In some circumstances CTA10/S935 deem into existence consolidated group accounts drawn up in accordance with GAAP to determine whether leasing arrangements count as a finance lease. For example where the lease is correctly regarded as an operating lease in lessor company’s accounts (or would have been if drawn up under GAAP) but would have been treated as a finance lease in group consolidated accounts if they had been prepared under GAAP.