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HMRC internal manual

Business Leasing Manual

From
HM Revenue & Customs
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Sale of lessor companies and similar arrangements: anti-avoidance: interaction between sections 435 and 436 CTA2010

Sections 435 and 436 CTA2010

It is possible that the provisions in section 436 will cover an arrangement also covered by the provisions in section 435.

The arrangement described in BLM82050 would be just such a situation. In this situation the reduction in the balance sheet figure is caused by the existence of the liability. Ignoring the effect of the transaction under section 435 will have exactly the same effect as ignoring the liability under section 436.