Chapter BLM22075
Published date | 10 April 2016 |
Record Number | BLM22075 |
Court | HM Revenue & Customs |
Issuer | HM Revenue & Customs |
In the case of a lease that is not a long funding lease then a change in the accounting classification is, of itself, not very significant for tax purposes (see BLM32065). It may, however, indicate changes have been made to the lease which indicate that, in fact, a new lease has been entered into - see BLM22010.
However without specific rules it might be possible for a lessor to enter into a lease that is correctly classified as an operating lease at inception but then take out a residual value guarantee shortly afterwards. Had the guarantee been taken out - or been planned - at inception the lease may have been a finance lease and so is more likely to be a long funding lease.
CAA01/S70YD applies where
- a lessor under a lease that is not a long funding lease,
- enters into arrangements which increase (perhaps from nil) the proportion...
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