Skip to content
Solved
SearchBrowse
Sign in

Contents

Official guidance
Business Leasing Manual

BLM71000 · ‘Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes

  • BLM71001 · Summary
  • BLM71005 · ‘Income-into-capital’ schemes and back loaded leases: ‘Income-into-capital’ schemes: comparison with ordinary loan
  • BLM71010 · How the typical scheme works
  • BLM71015 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: rental profiles
  • BLM71020 · ’Income-into-capital’ schemes and back loaded lease: 'Income-into-capital' schemes: capital allowances, part 1 of 2
  • BLM71025 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: the effect of the deal, part 2 of 2
  • BLM71030 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: objectionable features
  • BLM71035 · ’Income-into-capital’ schemes and back-loaded leases: 'Income-into-capital' schemes: other features
  • BLM71040 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: borrower carries all the tax risks
  • BLM71045 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: commercial reality
  • BLM71050 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: finance lessee's position
  • BLM71055 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: purchase option
  • BLM71060 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: lessee's accountancy treatment
  • BLM71065 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: lessee's group
  • BLM71300 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: example, part 1 of 5
  • BLM71305 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: example, part 2 of 5 -accountancy treatment - detail
  • BLM71310 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: example, part 3 of 5 - lessor's tax treatment
  • BLM71315 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: example part 4 of 5, tax treatment - purchase option
  • BLM71320 · ’Income-into-capital’ schemes and back loaded leases: 'income-into-capital' schemes: example part 5 of 5 - effect of Chapter 2 of Part 21 of CTA 2010
  • BLM71400 · ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: Purchase options
  1. ‘Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: contents
  2. ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: example, part 1 of 5

BLM71300 | ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: example, part 1 of 5

From HM Revenue & Customs · Business Leasing Manual

Example

This example shows more detail of the practical effects of an ‘income-into-capital’ scheme. The following steps are agreed in advance between the parties-a finance lessor which is part of a major banking group (Bank) and a finance lessee (the Borrower):

  • Borrower owns a property freehold and grants a 999 years lease to Bank for £70 million. No rent is payable under this lease. That £70 million is the ‘loan’.

  • Bank’s funding cost (interest payable by Bank) is £9 million a year.

  • Bank leases the property back to Borrower for 30 years in return for rent. The rent is low until the end of year 7 of the lease when it increases so that the rents over the remainder of the lease will repay the ‘loan’ with ‘interest’. The first seven years’ rent amounts to £40 million.

  • Bank grants an option to a subsidiary of Borrower called Holder: this is the company that holds the option to buy back the leased asset. The option enables Holder to acquire the 999 years lease from Bank after 7 years for £100 million.

The important point here is that, if the option is exercised, Bank will get its money in two ways; first, as rent under the lease (£40 million) and, second, as proceeds of sale when Holder exercises its option (for £100 million) - this amounts to £140 million in total. In this way, Bank gets back the £70 million spent on acquiring the 999 years lease and £70 million representing ‘interest’.

PreviousNext
PrivacyTerms