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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: Lease changes: catching-up charge - 'existing’ operating lease becomes a lease with Chapter 2 of Part 21 of CTA 2010

CTA10/S923 also applies in terms where ‘pre-26 November 1996’ operating leases become Chapter 2 of Part 21 of CTA 2010 leases after 26 November 1996. But in those circumstances there will be no ‘catching up’ charge under the paragraph nor any cumulative excesses to be brought forward from the periods when the lease was an operating lease.