beta This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Oil Taxation Manual

Corporation Tax Ring Fence: Sale and Leaseback of assets


CTA10\S288 provides that where a sale and leaseback transaction has occurred, the finance charge element of lease rentals will not be allowable as a deduction in the CT ring fence unless the proceeds from the sale of the asset are applied to finance North Sea activities.

Expenditure disallowed is treated as a non-trading debit in respect of a loan relationship of the lessee for that accounting period and is therefore deductible for non-ring fence CT purposes.