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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 lease: Condition B: leasing arrangements

It is important to recognise that the major lump sum need not be provided for under the terms of the lease itself. Very often it may be governed by separate option agreements granted to the lessee or companies in the lessee group. Option agreements of that sort will count as ‘leasing arrangements’. See BLM70430 for a discussion of the definition of leasing arrangements.