BLM82030 - Sale of lessor companies and similar arrangements: anti- avoidance: manipulation of balance sheet values - introduction


Balance sheet values may be manipulated to avoid the charge under Schedule 10. If the amounts shown in the balance sheet in respect of plant or machinery are depressed the PM amount is decreased, perhaps to nil. Where this is the case, two consequences could flow:

  • The company may no longer be regarded as carrying on the business of leasing plant or machinery, see BLM80100 onwards.
  • Even if it is still regarded as carrying on the business of leasing plant or machinery the Schedule 10 charge is reduced or eliminated.

This avoidance activity is countered by FA06/SCH10/PARA38A and PARA38B.