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HMRC internal manual

Business Leasing Manual

’Income-into-capital’ schemes and back loaded leases: Capital allowances: double taxation

You should be aware of the general assurance about double taxation in the Tax Bulletin article of April 1997 (see BLM72140):

`It has been suggested to us that in some circumstances the rules in Schedule 12 (now Part 21 of CTA 2010), in particular the use of the consolidated accounts, could lead to taxation of the same sums more than once. The rules in the Schedule were not intended to lead to double taxation and we have not identified specific situations where double taxation can occur. We do not propose to argue that double taxation can arise.`

A specific - limited exception - to the proposition that double taxation will not arise in these circumstances is set out in BLM73045.