Long funding leases

Produced by Tolley in association with Martin Wilson and Steven Bone
Owner-Managed Businesses
Guidance

Long funding leases

Produced by Tolley in association with Martin Wilson and Steven Bone
Owner-Managed Businesses
Guidance
imgtext

The concept underlying the capital allowances treatment of a long funding lease is that the lessor (the legal owner of the plant and machinery) is effectively lending money to the lessee (the person using the asset) to enable the lessee to buy the plant and machinery. The most significant feature of the rules is that, provided certain conditions are met, capital allowances are available to the lessee rather than the lessor. However, there are extensive exceptions to the long funding lease rules, notably affecting fixtures and other plant included in, or sold with, property.

A lessee does not have to come within the regime if they do not want to, but can instead claim a deduction for lease rentals in the usual way.

There is provision for a lessor to elect that all new leases entered into by it shall be treated as long funding leases (if they would not otherwise be so). This does not apply to leases of cars or of assets which cost more than £10m.

For more information on long funding leases,

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Martin Wilson
Martin Wilson


Martin Wilson, specialised in capital allowances for 25 years before retirement. He is the author of numerous published works on the subject, including Bloomsbury's Capital Allowances: Transactions & Planning, and the capital allowances content of LexisPSL, Tolley's Tax Guidance, Tolley's Tax Planning and Simon's Tax Planning.

Steven Bone
Steven Bone linkedinicon twittericon

Director at Gateley Capitus


Steven is a tax-qualified Chartered Surveyor who has specialised in tax incentives, including capital allowances and land remediation relief for over 20 years. Previously he held senior specialist positions in 'Big 4' and national mid-tier accountancy firms. Capital allowances underpin income tax and corporation tax calculations by giving tax relief for money spent to buy, build or alter commercial property.Steven works with owner-occupiers, investors and their advisers to provide capital allowances opinions, transaction support and specialist valuations for all types of property.  This includes resolving HM Revenue capital allowances enquiries and giving expert evidence to tribunals and courts.Steven has contributed to many articles and books, including: Bloomsbury Professional's Capital Allowances, Tolley's Tax Planning, RICS's official Guidance Note for surveyors on Capital Allowances and Land Remediation Relief, and Practical Law Company's Practice Note on Commercial Property Standard Enquiry 32 dealing with capital allowances.

Powered by Tolley+

Popular Articles

Married couple’s allowance

Married couple’s allowanceThe married couple’s allowance (MCA) is only available if one of the two spouses or civil partners was born before 6 April 1935. This means that one member of the couple must be at least 89 years old on 5 April 2024 to qualify for an allowance in the 2023/24 tax year.There

14 Jul 2020 12:13 | Produced by Tolley Read more Read more

Long service awards

Long service awardsEmployee recognition by an employer can be an important motivational tool, as well as having a positive effect on retention. Most employer awards made to an employee are treated as taxable earnings under ITEPA 2003, s 62 or as a benefit under ITEPA 2003, s 201 because they are

14 Jul 2020 12:11 | Produced by Tolley Read more Read more

VAT registration ― artificial separation of business activities (disaggregation)

VAT registration ― artificial separation of business activities (disaggregation)This guidance note should be read in conjunction with the VAT registration ― compulsory guidance note and is relevant to persons established or resident in the UK. Persons that are not established or resident in the UK

14 Jul 2020 13:57 | Produced by Tolley Read more Read more