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HMRC internal manual

Business Leasing Manual

’Income-into-capital’ schemes and back loaded leases: Lease changes: 'new' Chapter 3 of Part 21 of CTA 2010 lease becomes Chapter 2 lease

Where a ‘post-25 November 1996’ lease which is initially within Chapter 3 of Part 21 of CTA 2010 (because it is treated as a finance lease) subsequently becomes a lease within Chapter 2 of Part 21 of CTA 2010, it is treated as falling within Chapter 2 from that point. Cumulative excesses at the point of the change in status are recognised for Chapter 2 purposes by virtue of CTA10/S924.