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HMRC internal manual

Business Leasing Manual

Defining long funding leases: plant or machinery leased with other assets: derived leases - terms and rentals

Once the existence of a derived lease has been established it is necessary to establish what that derived lease looks like. In particular it is necessary to establish the term of each derived lease and the rentals attributable to it.

Clearly, the term of any derived lease cannot exceed the term of the mixed lease from which it derived.

Similarly, the rentals payable under each derived lease can only be treated as paid when rentals are payable under the mixed lease and on any one payment date the totals of the rentals payable under each derived lease must equal the amount payable under the mixed lease.

Within those constraints, CAA01/S70M sets out the way in which the term and rentals for the derived lease are to be calculated. Once that has been done, the rules in CAA01/S70G establish whether the derived lease is a long funding lease.