BLM71050 - ’Income-into-capital’ schemes and back loaded leases: 'Income-into-capital' schemes: finance lessee's position
The lease in an income-into-capital scheme is likely to be a finance lease from the lessee’s (borrower’s) end and relief for payments is given on the normal SP3/91 basis. However, any sum paid for the property under an option is capital, and so no revenue deduction is due for the payment.