188体育

The principal targets of the catching-up charge in CTA10/S923 are 鈥榩re-26 November 1996鈥� finance leases (which would come within Chapter 3 of Part 21 of CTA 2010 if they were 鈥榩ost-25 November 1996鈥� leases) where the leasing arrangements are changed late in the term of the lease to enable the lessor to be partly paid out by a 鈥榤ajor lump sum鈥� rather than by means of rentals. A major lump sum is a sum which is regarded for accountancy purposes as comprising not only the repayment of the lessor鈥檚 investment but also 鈥榠nterest鈥� on it (see BLM70516 onwards). If Chapter 2 of Part 21 of CTA 2010 was simply applied to 鈥榓ccountancy rental earnings鈥� accruing prior to the change in the arrangements which caused the lease to come within Chapter 2, a substantial amount of rental income accruing prior to the change could be turned into capital.