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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: 'Income-into-capital' schemes: Purchase options: no formal option

In some income-into-capital schemes there may conceivably be no formal option but there are other arrangements which make it likely that the Borrower will re-acquire the leased asset when the ‘loan’ is ‘repaid’ or at around that time.

Some leases may relate to fixtures where the asset never ceases, as a matter of general law, to belong to the Borrower group.