BLM01015 | Introduction: anti-avoidance rules: asset other than land

This manual is being updated to reflect FRS 102 (2024 amendments). For guidance on the tax treatment of accounts prepared under IFRS 16 or the revised FRS 102, please refer to pages within the BLM50000 chapter.

CTA10/Ss863-886 / ITA07/Ss681C-681DP (previously ICTA88/S781 - ICTA88/S785) counters arrangements involving the leasing of assets other than land. Such arrangements are, in general, designed to produce

• a capital receipt to the trader (or an associate), and

• the allowance to the trader, in the early years of the lease, of relief in respect of an inflated rental.

The legislation may also apply where assets are sold at overvalue followed by a leaseback at an inflated rental

Guidance is at BIM61200 onwards.