Part 9Leasing plant or machinery

Chapter 4Sales of lessors: leasing business carried on by a company in partnership

Qualifying changes of ownership in relation to partner company

425Partner company's income and matching expense in different accounting periods

1

This section applies if on any day (“the relevant day”)—

a

a company carries on a business of leasing plant or machinery in partnership with other persons (see sections 410 to 414),

b

the company is within the charge to corporation tax in respect of the business, and

c

there is a qualifying change of ownership in relation to the company.

2

On the relevant day—

a

the company is treated as receiving an amount of income, and

b

the accounting period of the company ends.

3

The income—

a

is treated as a receipt of the company's notional business (see section 417(6)), and

b

is brought into account in calculating for corporation tax purposes the profits of that business for that accounting period.

4

On the day following the relevant day—

a

the company is treated as incurring an expense, and

b

a new accounting period of the company begins.

5

The expense—

a

is treated as an expense of the company's notional business, and

b

is allowed as a deduction in calculating for corporation tax purposes the profits of that business for that new accounting period.

6

This section is supplemented by sections 426 to 428.