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HMRC internal manual

Business Leasing Manual

’Income-into-capital’ schemes and back loaded leases: Capital allowances: contributions to lessor's capital expenditure

CTA10/S922 deals with the situation where relief has been given under CAA01/Ss 537 to 542 to a contributor for sums paid to fund a lessor’s expenditure on a leased asset and a major lump sum is receivable in respect of that asset. In those circumstances allowances granted to the lessor are recaptured in the same way and to the same extent as the lessor’s allowances would have been clawed back if they had been entitled to them in the first place.

Without this provision it would have been possible to side-step CTA10/SS717-922 by arranging for, say, another member of the lessor group to claim capital allowances in respect of the lessor’s expenditure rather than the lessor itself. The benefit of those capital allowances would then have been retained even though the lessor’s outlay would have been recouped by means of the major lump sum.