Commentary

B3.340C Anti-avoidance—arrangements for the transfer of leases of plant and machinery

Business tax
Business tax | Commentary

B3.340C Anti-avoidance—arrangements for the transfer of leases of plant and machinery

Business tax | Commentary

B3.340C Anti-avoidance—arrangements for the transfer of leases of plant and machinery

There are provisions1 designed to counteract certain benefits derived from the exploitation of capital allowances for plant and machinery through the medium of leasing operations and associated arrangements. Broadly, they attack schemes whereby a group of companies which has taxable profits takes the benefit of the tax loss created by first-year allowances after having arranged for the leasing contract (which will subsequently show taxable profits) to be transferred to another group which can use the profits against its losses.

Any loss incurred by a company on a leasing contract may

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial