It is understood that HMRC was originally of the view that all income derived from the leasing of plant or machinery that is affixed to land in such a manner as to become a fixture is, as a matter of law, to be taxed as property income and not as trading income, and furthermore that, as property income, such income does not arise from a trade carried on by the lessor. HMRC was believed to take this view in principle even in cases where the equipment was leased separately from the land to which it was affixed (e.g. where it was leased by an equipment lessor pursuant to CAA 2001, s. 177: see ¶1151-800), and not only where it was leased as part of the lease of the relevant land.

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