Example
Taking the simple example at
BLM31210, in year 1 the lessor might pay
interest of £2.5m (£50m at 5%). It will also be entitled
to writing down allowances of £12.5m (£50m at 25%),
therefore in year 1 it will make a tax loss of:
| Gross rents receivable | £4.14m |
| Less interest payable | £2.50m |
| Gross profit | £1.64m |
| Less capital allowances | £12.50m |
| Tax loss | (£10.86m) |
Assuming the ship was sold for £35m in year 10, then
over the 10 years a very simple view of the tax position might look
like:
| Year | Rental income | Interest paid | WDAs (BC) | Tax profit (loss) | Tax paid (repaid) |
| 1 | 4.14 | 2.50 | 12.50 | (10.86) | (3.26) |
| 2 | 4.14 | 2.44 | 9.38 | (7.68) | (2.30) |
| 3 | 4.14 | 2.38 | 7.03 | (5.28) | (1.58) |
| 4 | 4.14 | 2.32 | 5.27 | (3.45) | (1.04) |
| 5 | 4.14 | 2.25 | 3.96 | (2.07) | (0.62) |
| 6 | 4.14 | 2.18 | 2.97 | (1.01) | (0.30) |
| 7 | 4.14 | 2.10 | 2.22 | (0.19) | (0.06) |
| 8 | 4.14 | 2.02 | 1.67 | 0.45 | 0.13 |
| 9 | 4.14 | 1.94 | 1.25 | 0.95 | 0.28 |
| 10 | 4.14 | 1.85 | (31.25) | 33.54 | 10.06 |
| Total | 41.38 | 21.98 | 15.00 | 4.40 | 1.32 |
The total taxable profit of £4.40m is the difference
between the interest paid (£26.38m – see
BLM30210) and the assumed interest
element of the lease rentals (£21.98m).
The tax-timing advantage is clear and is, in principle, very
similar to that which arises on a finance lease. The value of that
benefit will be factored into the lease rentals and the tax /
rental model will become far more complex than shown here.
Incidentally, this simple model illustrates the benefits that
would arise if the balancing charge was avoided in year 10 as
around £10m in tax is payable in that year (following net tax
savings of £8.74m).
