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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 D: consolidated group accounts

Where the accounts of a connected person or consolidated group accounts are (or would be) drawn up for a different period from those of the lessor CTA10/S931 makes provision for time apportionment, if necessary, to reach comparable figures. Such an exercise will not be necessary if, in a particular case, some more accurate method is available.

In practice, it will be unusual to need to substitute figures from consolidated or connected person accounts. The need is most likely to arise in a case where the lessor’s own accounts correctly show the lease as an operating lease but where it is correctly classified as a finance lease from the wider perspective of the group.