BLM71030 - 바카라 사이트™Income-into-capital바카라 사이트™ schemes and back loaded leases: 'Income-into-capital' schemes: objectionable features
Prior to FA06, successive 바카라 사이트s allowed finance leasing to enjoy a favourable fiscal rĂ©gime. Finance lessors were given capital allowances on assets which, in economic and commercial substance, they do not own. The quid pro quo was that the lessor should pay tax on the 바카라 사이트˜interest바카라 사이트™ and 바카라 사이트˜capital바카라 사이트™ elements in the lease rentals.
Following FA06, some finance leases (long funding leases) do not qualify for capital allowances.
The 바카라 사이트˜income-into-capital바카라 사이트™ schemes avoided tax on both elements of the rentals and arrangements which do this are objectionable. They turned deferral into a permanent loss of tax. Although FA97/Sch12 (now Part 21 CTA 2010) stopped some schemes, many more were developed, see the guidance at BLM80000.