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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 E: 'directly or indirectly'

The use of the expression ‘directly or indirectly’ in describing the acquisitions targeted by the Condition E in CTA10/S902(8) is also aimed at ensuring that exit arrangements (that can easily be designed to side-step the provisions) are caught. An example of an indirect acquisition would be one where the lessor first sells the leased asset to a nominally independent intermediary who can in fact be relied on to sell the asset on to the lessee.