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HMRC internal manual

Business Leasing Manual

From
HM Revenue & Customs
Updated
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Sale of lessor companies and similar arrangements: change of ownership: exceptions to qualifying change of ownership: election out of charge: outline of restrictions

Sections 398D to 398E CTA2010

This guidance applies where the relevant day falls on or after 5 December 2009 and before 23 March 2011.

The restrictions imposed by an election out of the charge cover the following areas:

  • Set off of losses against profits of the company
  • Availability of capital allowances
  • Entry into the tonnage tax regime
  • Disposal values when plant or machinery is transferred out of the company.