BLM42025 - Taxation of long funding leases: lessees: lease rental restriction - introduction


Lessees under long funding leases obtain relief for part of the lease rental payments by way of capital allowances.

It follows that it is necessary to restrict the relief that would otherwise be available for rentals payable under the lease.

The taxation of income and expenditure is governed by ICTA for corporation tax and by ITTOIA for income tax. The following guidance refers only to ICTA, but essentially the same principles apply to the equivalent sections in ITTOIA.

The equivalent sections are

  • ICTA88/S502I = ITTOIA05/S148G
  • ICTA88/S502J = ITTOIA05/S148H
  • ICTA88/S502K = ITTOIA05/S148I