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Legislation
Income Tax Act 2007

Chapter 6 Avoidance involving leases of plant and machinery

  • Section 809ZA Plant and machinery leases: capital receipts to be treated as income
  • Section 809ZB Section 809ZA: interpretation
  • Section 809ZC Section 809ZA: lease of plant and machinery and other property
  • Section 809ZD Section 809ZA: expectation that relevant capital payment will not be paid
  • Section 809ZE Capital payment”, “relevant capital payment” etc
  • Section 809ZF Further interpretation of section 809ZA etc
  • Section 809ZFA Consideration for taking over payment obligations as lessee treated as income
  1. Chapter 6 · Avoidance involving leases of plant and machinery
  2. Section 809ZA: expectation that relevant capital payment will not be paid

Section 809ZD | Section 809ZA: expectation that relevant capital payment will not be paid

From legislation.gov.uk

(1)This section applies for income tax purposes if—

(a)section 809ZA applies by virtue of subsection (1)(a) of that section, and

(b)at any time, the lessor reasonably expects that the relevant capital payment will not be paid (or will not be paid in full).

(2)For the purposes of calculating the profits of the lessor, a deduction is allowed for the period of account which includes that time.

(3)The amount of the deduction is equal to the amount reasonably expected not to be paid.

(4)No other deduction is allowed in respect of the matters mentioned in subsection (1).

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