BLM35075 - Taxation of leases that are not long funding leases: sale and leaseback: deductibility of rents under leaseback - 'income-into-capital' schemes
Particular issues regarding the deduction of rentals arise where the sale and lease-back transaction is such that the lessor바카라 사이트™s tax treatment is subject to Chapters 1 and 2 Part 21 CTA 2010 / Part 11A ITA 2007, that is one where the arrangements enable the lessor to take part of the return on its investment in capital form (바카라 사이트˜income-into-capital바카라 사이트™ schemes). An example of a typical 바카라 사이트˜income-into-capital바카라 사이트™ scheme is at BLM33020.
Points to consider on the deduction of the lessee바카라 사이트™s rentals are
- whether or not it is appropriate to recognise rental payments on the basis that this is a finance lease, rather than an operating lease - see BLM33025, and
- what the payments are for - see BLM33030 onwards.