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HMRC internal manual

Business Leasing Manual

’Income-into-capital’ schemes and back loaded leases: Lease changes: introduction

In general, special rules are not needed in Part 21 of CTA 2010 to deal with situations where the terms of leasing arrangements and/or their accountancy treatment change. The exception is where a lease in existence immediately before 26 November 1996 initially does not come within Chapter 2 but subsequently does so. CTA10/S923 imposes a catching-up charge in these circumstances and this is described in BLM74335.