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Leased plant and machinery: mismatched chains of leases and leases granted at a premium
Practical Law UK Legal Update 8-379-8987 (Approx. 5 pages)
Leased plant and machinery: mismatched chains of leases and leases granted at a premium
by PLC Tax
| Published on 18 Dec 2007 • England, Wales |
On 13 December 2007, HM Revenue & Customs (HMRC) published a Technical Note containing draft anti-avoidance legislation aimed at two types of arrangements relating to leased plant and machinery. The legislation affects:
1. Arrangements involving head leases and sub-leases which create tax losses where there are no commercial losses (mismatched chains of leases).
2. Arrangements involving the grant of a lease for a premium.
The changes take effect from 13 December 2007. The draft legislation in the Technical Note will be included in the Finance Bill 2008.
HMRC has invited comments to be received no later than 14 February 2008.