In general, special rules are not needed in FA97/Sch12 to
deal with situations where the terms of leasing arrangements and/or
their accountancy treatment change. The exception is where a lease
in existence immediately before 26 November 1996 initially does not
come within Part I but subsequently does so. FA97/Sch12/Para13
imposes a catching-up charge in these circumstances and this is
described in
BLM74335.