BLM01025 | Introduction: anti-avoidance rules: back-loaded leases and 'income into capital' schemes

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.

Part 21 CTA10 / Part 11A ITA07 counters two types of scheme:

• back-loaded leases designed to defer taxation of income, and

• ‘income-into-capital’ schemes designed to turn taxable income into (effectively untaxed) capital receipts.

Guidance is in this manual at BLM70000 onwards.