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Contents

Official guidance
Business Leasing Manual

BLM70005 · ‘Income-into-capital’ schemes and back loaded leases: Introduction to back-loaded leases

  • BLM70006 · ‘Income-into-capital’ schemes and back loaded leases: Legislation
  • BLM70010 · Why avoidance
  • BLM70015 · Pre-FA97/Sch 12
  • BLM70020 · Lessors' earnings within property income
  • BLM70025 · Lessors' within trading income
  • BLM70030 · Comparison of tax and commercial profit
  • BLM70035 · Worked example of commercial and tax profits pre FA97/Sch12
  • BLM70040 · Negative depreciation
  1. ‘Income-into-capital’ schemes and back loaded leases: Introduction to back-loaded leases: contents
  2. ‘Income-into-capital’ schemes and back loaded leases: Introduction to back-loaded leases: lessors' earnings within property income

BLM70020 | ‘Income-into-capital’ schemes and back loaded leases: Introduction to back-loaded leases: lessors' earnings within property income

From HM Revenue & Customs · Business Leasing Manual

Many, if not quite all, of the finance leases in ‘income-into-capital’ schemes involved real property assets. By exploiting the differences between the then ‘entitlement’ basis for property income and the ‘accruals’ basis, it was easy to ensure that the rentals taxable in any period were the low amount desired by the lessor even though they were reporting higher earnings in their commercial accounts.

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