Finance Leasing Manual - FLM25.04
SSAP21 Income recognition for finance leases
As explained at FLM4.14, SSAP 21 requires the 'interest' element
in finance lease rentals to be recognised each year 'so as to
produce a constant periodic rate of charge on the remaining balance
of the [loan] obligation'. This produces a declining amount of net
profit ('interest') each year if the lease rentals are structured
like a repayment mortgage. Where the rentals payable are the same
each year, the gross rent actually due for each period will be more
than the SSAP 21 'interest' earnings.
Lessors accept that the tax charge falls on the full amount
of the 'interest' they recognise as commercial earnings plus any
capital element in the rental. (The capital element in the rental
is part of the tax earnings but not part of the commercial
earnings-it is a repayment of the 'loan' the lessor has made: see
FLM4.10). Tax problems arise where the rentals payable are less
than the accountancy earnings. This can happen during the
construction period of major assets when no rentals are due or
where there are back-loaded (or rising 'stepped') payment terms,
see FLM25.09.
