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HMRC internal manual

Business Leasing Manual

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HM Revenue & Customs
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’Income-into-capital’ schemes and back loaded leases: Relief for set-offs against rentals: disposal of asset 'representing' leased asset

The definition of an asset which ‘represents’ a leased asset in CTA10/S934 is drawn in wide terms and is discussed at BLM70655. One example of the disposal of such an asset would be the sale of all the shares in a lessor company invested wholly or mainly in leased assets to which Part 21 of CTA 2010 applies. Cumulative accountancy rental excess can be deducted from the consideration on such a disposal as it can on a disposal of the leased asset itself.