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HMRC internal manual

Business Leasing Manual

‘Income-into-capital’ schemes and back loaded leases: Back loaded leases: accountancy rental earnings

CTA10/S897 provides that the accountancy rental earnings for a period of account of the lessor are the greatest of the following:

  • the rental earnings in the lessor’s accounts;
  • the rental earnings in a connected person’s accounts;
  • the rental earnings in the consolidated group accounts of a group of which the lessor is a member.

The accounts in question are those correctly drawn up in accordance with GAAP. You should apply BLM70485 in determining to what extent it is possible to deem into existence figures which are different from those in the actual accounts.