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HMRC internal manual

Business Leasing Manual

From
HM Revenue & Customs
Updated
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Taxation of leases that are not long funding leases: finance lessees: importance of lease term: no secondary period: back-loading of rentals

Leases with no secondary lease period are sometimes coupled with the back-loading of lease rental payments. The rentals in the early years may be less than the financing costs. If so, there may be tax consequences for the lessor under Part 21 CTA 2010 / Part 11A ITA 2007 (see BLM70000 onwards) which you should draw to the attention of the lessor’s district.