BLM73010 - 바카라 사이트™Income-into-capital바카라 사이트™ schemes and back loaded leases: Capital allowances: disposal proceeds more than cost of asset

The provisions in CTA10/SS916-922 are triggered by the occurrence of an occasion on which a 바카라 사이트˜major lump sum바카라 사이트™, as defined in Condition B at CTA10/S902(5), becomes payable (see BLM73005). On such an occasion the major lump sum is brought into account in order to recapture any statutory allowance for capital expenditure on the leased asset concerned. Since such allowances cannot be given on more than the cost of the asset there are rules in Sections 916-922 to ensure that any excess of the major lump sum over the cost of the leased asset qualifying for allowances is left out of account.

In general, no further rules are needed to ensure that the same sums are not brought into account twice - for example, once under 바카라 사이트˜negative depreciation바카라 사이트™ (BLM70845) effectively charged to tax under CTA10/S905 and once under the disposal adjustment rules for capital allowances, as extended by Sections 916-922. This is because there is no overlap between the sums involved. 바카라 사이트˜Negative depreciation바카라 사이트™ is reflected in the proceeds obtained from the disposal of a leased asset in excess of the lessor바카라 사이트™s original investment in that asset. That excess is excluded from the disposal proceeds taken into account for capital allowances.