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HMRC internal manual

Corporate Intangibles Research and Development Manual

HM Revenue & Customs
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Intangible assets: introduction: finance leasing

The corporate intangible assets regime also applies to companies that are finance lessors of intangible assets. The detailed legislation is in regulations, SI2002/1967 (see CIRD27090), made under powers set out in CTA09/PART8.

The new rules are likely to be predominantly of interest to specialist leasing companies. They incorporate protection against attempts to use sale and leaseback transactions to get around the rules keeping existing assets outside the regime.

There is also a rule that if intangible fixed assets are leased to concerns that use them in a trade or business subject to income tax then the assets remain outside the regime.

There is more guidance on the finance leasing provisions at CIRD27000 onwards.