In most cases it will be immediately apparent that a company
is a lessor company and that it has changed hands. Typically the
company owns only assets that are leased out to others and it is a
100% subsidiary sold outright. However, the legislation is designed
to deal with more complex structures such as partnerships and
consortia and prevents groups from arranging their affairs to
exploit alternative methods of ensuring that losses of the leasing
business are tax effective while profits fall out of tax.
To decide whether a transaction is caught by Schedule 10 you
need to answer two questions:
