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HMRC internal manual

Business Leasing Manual

Taxation of leases that are not long funding leases: legal expenses: capital allowances position

The capital allowances position does not normally determine the treatment of something for trading income purposes and indeed depends on a specific statutory rule, the ‘ownership’ test in CAA01, which is interpreted as a test of legal ownership. The view that the different interests in an asset (leasehold, reversionary and so on) constitute separate assets is better established in the real property field than it is in the case of chattels.