‘Income-into-capital’ schemes and back loaded lease: Definition of a Chapter 2 of Part 21 of CTA 2010 lease: Condition D: definition of 'accountancy rental earnings'
CTA10/S897 provides that the ‘accountancy rental earnings’ for a period of account of the lessor are the greatest of the following:
- the rental earnings in the lessor’s accounts;
- the rental earnings in a connected person’s accounts;
- the rental earnings in the consolidated group accounts of a group of which the lessor is a member.
The accounts in question are those correctly drawn up in accordance with GAAP. BLM70485 should be applied in determining to what extent it is possible to deem into existence figures, prepared in accordance with GAAP, which are different from those in the actual accounts.
For the meaning of ‘rental earnings’, see BLM70575.