Chapter BIM64145

Published date22 November 2013
Record NumberBIM64145
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

A private sector operator, whose trade includes the provision of design, construction and maintenance services, enters into a PFI contract with a public sector purchaser to build a street lighting system and maintain it for 30 years. The trade commences when the PFI agreements are signed (see BIM64065). In return the operator receives an annual service payment, the unitary charge, which commences after the system is completed.

Accounting period 1

The street-lighting system is completed during the first accounting period.

For tax purposes, the design and construction costs are revenue expenditure. The system is not a fixed capital asset of the operator’s trade (see BIM64025 onwards). For accounting purposes the example assumes that it is reported as a finance debtor on the operator’s balance sheet, under FRS5 Application Note F, at a figure of £90m representing cost (see BIM64070 onwards).

Dr Finance debtor £90m Cr Bank £90m

A unitary payment of £15m is receivable in the accounting period.

For tax purposes the £15m is trading income for the provision of services. For FRS5 accounting purposes, £7m represents a part payment of the finance debtor and £8m represents operating income.

For accounting purposes, a figure representing accrued finance income, i.e. notional interest, on the finance debtor is calculated at £4m and credited to the profit and loss account. The corresponding debit is to the finance debtor (see BIM64125).

Dr Finance debtor £4m Cr P&L account (notional interest) £4m

The part payment of £7m is then credited to the finance debtor and the operating income of £8m is credited to the profit and loss account.

Dr Bank £15m Cr P&L account (operating income) £8m
Cr Finance debtor (part payment) £7m

For tax purposes we follow the accounting recognition of income in the profit and loss account, subject...

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