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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: return on investment

A ‘major lump sum’ must also include for accounting purposes a part which is treated under normal accountancy practice as ‘return on investment in respect of a finance lease’. In general you should view any part of a prospective major lump sum which is neither ‘rent’ nor repayment of investment in respect of the finance lease as ‘return on investment’. Accounting purposes and practice are to be understood as explained in BLM70445. Return on investment need not include the whole of that return; part is sufficient.