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Chapter BLM71300

Document Cited in Related
Vincent
Published date10 April 2016
Record NumberBLM71300
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

Example

This example shows more detail of the practical effects of an ‘income-into-capital’ scheme. The following steps are agreed in advance between the parties-a finance lessor which is part of a major banking group (Bank) and a finance lessee (the Borrower):

  • Borrower owns a property freehold and grants a 999 years lease to Bank for £70 million. No rent is payable under this lease. That £70 million is the ‘loan’.
  • Bank’s funding cost (interest payable by Bank) is £9 million a year.
  • Bank leases the property back to Borrower for 30 years in return for rent. The rent is low until the end of year 7 of the lease when it increases so that the rents over the remainder of the lease will repay the ‘loan’ with ‘interest’. The first seven years’ rent amounts to £40 million.
  • Bank grants an option to a subsidiary of...

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