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HMRC internal manual

Business Leasing Manual

’Income-into-capital’ schemes and back loaded leases: Back loaded leases: alteration of lease granted before 26 November 1996

Where a lease granted prior to 26 November 1996 is said to have been revised subsequently so that ‘negative depreciation’ (the excess of accountancy rental earnings over normal rent) arises for the first time, you should consider whether the revision is so extensive as to amount to a new lease of the asset. You should report attempts to revise leases in this way to take advantage of the grand-fathering of existing leases to CTIS (CT&BIT).