Corporation Tax Act 2010 section 409

Introduction to Chapter

Section 409 introduces the rules that apply when a company carrying on a plant or machinery leasing business in partnership experiences either a change in its partnership interest or a change of ownership.

• The chapter applies to a company that leases plant or machinery in partnership with others and experiences either a qualifying change in its interest in the business or a qualifying change of ownership
• Where there is a qualifying change in the company's partnership interest, specific rules in sections 417 to 424 determine the tax consequences, including the recognition of income and matching expense
• Where there is a qualifying change of ownership of the company, a separate set of rules in sections 425 to 429 applies to deal with the timing of income and expense recognition
• Sections 410 to 414 set out how to determine whether a partnership business qualifies as a business of leasing plant or machinery on any given day, using defined terms such as "the relevant day", "the partner company" and "the partnership"