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HMRC internal manual

Business Leasing Manual

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‘Income-into-capital’ schemes and back loaded leases: Definition of a Chapter 2 of Part 21 of CTA 2010 lease: Condition E: existence of 'arrangements' or 'circumstances'

Condition E in CTA10/S902(8) is that certain ‘arrangements’ or ‘circumstances’ must exist. CTA10/S904 then describes them in detail. In either case (whether ‘arrangements’ or ‘circumstances’):

  • it is first necessary to identify a possible future event (see BLM70650);
  • then whether there are either arrangements or circumstances in being at the time under consideration making it sufficiently likely that the future event will occur (see BLM70670).

If so, Condition E is satisfied.