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DEREK JENKINS tax partner at PricewaterhouseCoopers analyses HMRC's technical note concerning the tax treatment of leased plant and machinery.

A NUMBER OF changes relating to the tax treatment of plant and machinery are planned by HMRC having been under discussion for a while. In essence HMRC's aim has been to confer tax ownership on the lessee and it is likely that the changes will impact on many companies in the UK particularly medium and large companies. To this end HMRC published on 21 July 2005 a technical note developing the proposal for the reform of lease taxation that was first published on 12 August 2003 and the subsequent note issued with the Pre-Budget Report 2004.
HMRC confirm in the note that the new régime will start in full for leases entered into on or after 1 April 2006. However ...