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Contents

Official guidance
Business Leasing Manual

BLM82000 · Sale of lessor companies and similar arrangements: anti-avoidance

  • BLM82005 · Tackling avoidance
  • BLM82010 · Meaning of ‘relevant leasing income’
  • BLM82015 · Application of section 432
  • BLM82020 · Sale of lessor companies and similar arrangements: anti- avoidance: losses carried forward derived from the expense (FA06/SCH10/PARA39)
  • BLM82025 · Relationship of Schedule 10 with CAA01/S228K (FA06/SCH10/PARA40)
  • BLM82030 · Manipulation of balance sheet values - introduction
  • BLM82035 · Manipulation of balance sheet values - main purpose test
  • BLM82037 · Manipulation of certain amounts
  • BLM82040 · Meaning of ‘arrangements’
  • BLM82045 · Meaning of ‘relevant tax advantage’
  • BLM82050 · Example showing effect of section 435 CTA2010
  • BLM82055 · Liabilities used to reduce balance sheet values Section 436 CTA2010
  • BLM82060 · Interaction between sections 435 and 436 CTA2010
  • BLM82065 · Restrictions on use of losses
  • BLM82070 · Losses carried forward derived from the expense
  1. Sale of lessor companies and similar arrangements: anti-avoidance: contents
  2. Sale of lessor companies and similar arrangements: anti-avoidance: interaction between sections 435 and 436 CTA2010

BLM82060 | Sale of lessor companies and similar arrangements: anti-avoidance: interaction between sections 435 and 436 CTA2010

From HM Revenue & Customs · Business Leasing Manual

Sections 435 and 436 CTA2010

It is possible that the provisions in section 436 will cover an arrangement also covered by the provisions in section 435.

The arrangement described in BLM82050 would be just such a situation. In this situation the reduction in the balance sheet figure is caused by the existence of the liability. Ignoring the effect of the transaction under section 435 will have exactly the same effect as ignoring the liability under section 436.

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