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HMRC internal manual

Business Leasing Manual

From
HM Revenue & Customs
Updated
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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: the future event

The future event is that:

  • the lessee or a person connected with the lessee: ‘may acquire, whether directly or indirectly, the leased asset, or an asset representing the leased asset, from the lessor or a person connected with the lessor’; and
  • ‘in connection with that acquisition the lessor or a person connected with him may receive, whether directly or indirectly, a qualifying lump sum from the lessee or a person connected with the lessee’ (CTA10/S904(1)(a) and (b)).

Guidance on ‘an asset representing a leased asset’ is at BLM70655; on a ‘qualifying lump sum’ is at BLM70660; and on the meaning of ‘directly or indirectly’ is at BLM70665.