BLM33035 - Taxation of leases that are not long funding leases: finance lessors: general taxation issues: ‘income-into-capital’ schemes - what the lessee's payments are for - group scheme

An additional point to consider on the treatment of rentals paid in income-into-capital schemes is whether the lessee’s payments are solely for the purposes of its trade. This may not be so if ultimately the rights of ownership of the asset are enjoyed elsewhere in the lessee’s group.