Corporation Tax Act 2010 section 364

"Starting value": general

Section 364 defines how to determine the "starting value" of plant or machinery for the purpose of calculating the periodic deduction available to a lessor under a long funding operating lease.

  • Where the lessor's only use of the asset has been leasing it under the current long funding operating lease, the starting value is the original cost the lessor incurred in acquiring the asset.
  • Where the asset was previously leased under another long funding operating lease, the starting value is the market value of the asset at the start of the current lease.
  • Where the asset was previously leased under a long funding finance lease, the starting value is the book value recorded in the lessor's financial records at the start of the current lease.
  • Where the asset was previously used for any other qualifying activity (not a long funding lease), the starting value is the lower of original cost and market value at the start of the current lease.

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