Anti-avoidance provisions

Capital payments in respect of

Commentary – Tax Reporter ¶228-550

Generally

Commentary – Tax Reporter ¶269-500

Reconstructions

Commentary – Tax Reporter ¶710-010

Taking over leasee payment obligation

Commentary – Tax Reporter ¶228-600

Capital allowances

Corporation tax

Commentary – Tax Reporter ¶236-110

Income tax

Commentary – Tax Reporter ¶236-105
HMRC Guidance – CA29450

Qualifying activities

Commentary – Tax Reporter ¶236-185

Corporation tax

Capital allowances

Commentary – Tax Reporter ¶236-110

Change of ownership

Commentary – Tax Reporter ¶731-570 ; Tax Reporter ¶731-580

Change of trader without change of ownership

Commentary – Tax Reporter ¶710-010

Generally

Commentary – Tax Reporter ¶711-120

Leasing partnership, profit sharing on allowable basis

Commentary – Tax Reporter ¶731-560

Reconstructions

Commentary – Tax Reporter ¶710-010 ; Tax Reporter ¶731-550

Exclusions

First-year allowances

Commentary – Tax Reporter ¶237-150
HMRC Guidance – CA23110
Case Law – Bourne (H.M. Inspector of Taxes) v. Auto School of Motoring (Norwich), Ltd Frazer (H.M. Inspector of Taxes) v. Trebilcock (trading as Vernons School of Motoring) Coghlin (H.M. Inspector of Taxes) v. Tobin (trading as Thanet School of Motoring)

Finance leases

– see Finance leases

Long funding leasing

– see Long funding leasing

Loss relief

Commentary – Tax Reporter ¶261-050

Rent factoring

Commentary – Tax Reporter ¶241-995

Short-term leasing

Commentary – Tax Reporter ¶240-700

Sideways relief, restriction

Commentary – Tax Reporter ¶261-050 ; Tax Reporter ¶290-800
HMRC Guidance – BIM85730