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Leasing Taxation Changes in FB 2008

Jonathan Vines Tax Partner and Tony Foley Tax Senior Manager KPMG LLP look in detail at the leasing taxation changes in Finance Bill 2008
Despite the early consultation documents from HMRC referring to lease simplification with the introduction on 1 April 2006 of the new regime for long funding leases (the LFL regime) the UK became one of the most complex jurisdictions in the world for the taxation of asset financing transactions. The non-LFL or 'old' regime for leases remains very much in place and the provisions included within the current Finance Bill impact both types of leases.
The LFL rules are highly prescriptive reflecting the approach taken for loan relationships derivative contracts and intangibles assets. Unlike the loan relationship provisions the rules are far from...

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