BLM70551 - 바카라 사이트˜Income-into-capital바카라 사이트™ schemes and back loaded leases: Definition of a Chapter 2 of Part 21 of CTA 2010 lease: Condition C: investment return not taxable as a normal rent

The condition CTA10/902(6) is intended to exclude cases where the whole, of what represents return on investment in a major lump sum, is taxable as rental income. In such a case there is no prospect that the 바카라 사이트˜interest바카라 사이트™ on the lessor바카라 사이트™s outlay on the leased asset (in substance a loan) will be received in capital form.

You should note the following detailed points:

  • the condition is not met (so that the lease is excluded from Part 21) only if it is the lessor who is taxable in this way - a connected person will not do;
  • all the return in the major lump sum must be taxable in the form of 바카라 사이트˜normal rent바카라 사이트™ - this is explained in BLM70600;
  • it must all be taxable for accounting periods ending with the one in which the period of account, in which the major lump sum may be paid, falls (or by the latest year of assessment for which that period of account is the basis period in an income tax case) - CTA10/S903(1).