BLM71310 - Schedule 12 FA 1997: 'income-into-capital' schemes: lessor's tax treatment, part 3 of 5


Example

The crucial benefit underpinning an income-into-capital scheme is that although the option excess is recognised as income it is not taxed as such. The tax computation omits the £30m of 'interest' in the £100m option price.

In tax terms Bank (the lessor) does not make a profit in any year. As can be seen from the tax computation below the tax losses amount to £23m which, at 33%, means that Bank can shelter £7.6m of their other profits from the Exchequer. The tax computation looks like this:

In £millions

Year12345678Total
Rent income0345677840
Expense0-9-9-9-9-9-9-9-63
Profit/(Loss)0-6-5-4-3-2-2-1-23