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Changes over time for: Cross Heading: Avoidance


Timeline of Changes
This timeline shows the different points in time where a change occurred. The dates will coincide with the earliest date on which the change (e.g an insertion, a repeal or a substitution) that was applied came into force. The first date in the timeline will usually be the earliest date when the provision came into force. In some cases the first date is 01/02/1991 (or for Northern Ireland legislation 01/01/2006). This date is our basedate. No versions before this date are available. For further information see the Editorial Practice Guide and Glossary under Help.
Status:
Point in time view as at 06/04/2024.
Changes to legislation:
Capital Allowances Act 2001, Cross Heading: Avoidance is up to date with all changes known to be in force on or before 07 March 2025. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.

Changes to Legislation
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[AvoidanceU.K.
70VTax avoidance involving international leasingU.K.
(1)This section applies where matters are so arranged that there are plant or machinery leases such that—
(a)under a lease by a non-resident, an asset is provided directly or indirectly to a resident,
(b)the direct provision of the asset to the resident is by a lease which, in the case of the resident, is a long funding lease or a lease to which section 67 (hire purchase etc) applies,
(c)the asset is used by the resident for the purpose of leasing it under a lease (the “relevant lease”) that would not (apart from this section) be a long funding lease in the case of the resident, and
(d)under the relevant lease, the asset is provided directly or indirectly (but by a lease) to a non-resident.
(2)Subsection (3) applies if the sole or main purpose of arranging matters in that way is to obtain a tax advantage by securing that allowances under this Part are available to a resident by virtue of—
(a)section 67 (hire purchase), or
(b)section 70A (long funding leases).
(3)In any such case, the relevant lease is deemed to be a long funding lease in the case of the resident who is the lessor under it.
(4)The reference in this section to a person obtaining a tax advantage (see section 577(4)) also includes a reference to a person obtaining a tax advantage within the meaning of [section 1139 of CTA 2010].
(5)In this section—
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