Until FA 2004, rentals under lease-back arrangements were
generally deductible as under any other finance lease, subject to
the guidance on defeasance arrangements (see
BLM35065). But even outside defeasance
situations it may sometimes be appropriate to consider in more
detail the deductibility of rents payable under the lease-back
under the general rules for deductions. There is also specific
legislation on sale and lease-back transactions in
ICTA88/Ss779-785, see
BIM61200 and
BIM61300.
Following FA 2004, deductions for rentals under leaseback
arrangements may be restricted by CAA01/S228B, see
CA28920.
