This section of the guidance deals with the lease and
leaseback of plant or machinery.
Lease and leaseback of plant or machinery almost certainly
always involves the avoidance of tax. CT & VAT (Technical) have
not seen any that do not involve the avoidance of tax, but that
does not mean none are entered into without intending to avoid tax.
Therefore, if you see a lease and leaseback transaction, make sure
you fully understand precisely what is involved and the tax
consequences that flow from it.
Lease and leaseback transactions can probably be divided into
two types: those where the head lease is for a premium (see
BLM36010), and those where it is not
(see
BLM36015).
