A further feature of 'income-into-capital' schemes is that
the accountancy profit may well appear in no individual group
company. The lessor company itself gets a small amount of rental
income which is all that it shows in its accounts. The parent of
the lessor company has a capital gain which, again, is all that it
shows in its accounts. The true earnings of the lessor group from
the lease only emerge in the results for the whole group - the
‘glossy’ accounts for the shareholders - which are not
the results of any individual company and therefore do not feature
in any tax computations. That is why it is necessary to look to the
overall commercial reality of the transactions shown only in the
consolidated group accounts.
