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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: leases ceasing to come within Chapter 2 - connected persons

CTA10/S933 provide provides that if a person (A) is connected with another person (B) at some time in the period which:

  • begins at the earliest time at which any of the arrangements were made; and
  • ends when the current lessor finally ceases to have an interest in the asset or any of the arrangements relating to it

they are to be regarded as connected throughout that period. These provisions are widely drafted in order to prevent the interposition of ‘stooges’ in a chain of assignments to get round the rule that the status of a lease is not re-tested on a transfer to a connected person.