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FA 2010 analysis – Sale of lessors

Speed read

Speed Read: FA 2010 made two changes to the sale of lessors regime in CTA 2010 Part 9. The first ensures that changes in the interests of members of a consortium trigger a qualifying change of ownership of any leasing company which is a qualifying 75% subsidiary of the consortium company rather than just a direct 90% subsidiary. The second provides lessors with an option to ring-fence their leasing business on a change of ownership as an alternative to suffering deemed income and expense under the sale of lessors rules.

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