BLM74615 - ’Income-into-capital� schemes and back loaded leases: Back loaded leases: first condition - lease granted on or after 26 November 1996

In practice this condition will have limited independent significance. If a lease is part of a ‘post-25 November 1996 scheme� (the second condition) it is extremely likely that the lease will have been granted on or after 26 November 1996. And if the lease is not part of a ‘post-25 November 1996 scheme�, Chapter 3 of Part 21 of CTA 2010 will not in any event apply since all the conditions have to be satisfied.

You should resist any contention that a lease which is admittedly a ‘post-25 November 1996 scheme� was granted prior to 26 November 1996.