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HMRC internal manual

Business Leasing Manual

HM Revenue & Customs
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‘Income-into-capital’ schemes and back loaded leases: Definition of a Chapter 2 of Part 21 of CTA 2010 lease: leases ceasing to come within Chapter 2 - assignments

Assignments breaking Chapter 2 of Part 21 of CTA 2010 treatment must be to a person who is not connected with any of the following:

  • the assignor;
  • any person who was the assignor at some time before the assignment; or
  • any person who becomes the lessor after the assignment if they do so pursuant to arrangements made by an earlier lessor or a connected person (CTA10/S901(3)-(5)).