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07 February 2012
A business manufactures plant and machinery for sale and leasing
Our client manufactures moveable plant and machinery partly to order and partly for stock and then sale. The items made may then be treated in one of the following three ways:
- there will be an outright sale to a third party;
- the plant will be used by a customer under the terms of an operating lease; or
- our client will sell the plant and machinery at its market value to a leasing company which will lease it back to our client under a finance lease agreement (not hire purchase) and our client will then lease it under an operating lease to their customer. There is no connection between our client the customers or the leasing company and no operator is supplied with the plant.
For tax purposes (as opposed to accounts purposes) the transfer...
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