BLM42030 - Taxation of long funding leases: lessees: limit on deductions (ICTA88/S502I)


In the case of a long funding finance lease, the lease rentals are restricted to the finance charges that are (or would be) shown in accounts prepared under GAAP.

The effect of this restriction is that the lessee obtains a deduction for the full amount of the rental payments, partly by way of a deduction for the finance charge element and partly by way of capital allowances. The capital allowances computations ensure that if a lease terminates early the appropriate capital allowances are available to the lessee, see CA23825.

The same principle applies where, exceptionally, the lease is accounted for as a loan.