Another occasion on which the normal treatment of a lessor under a long funding lease is not applied is where there is a scheme to create a substantial and artificial difference between the income a lessor under a long funding lease records for accounting purposes and his income from the same lease for tax purposes, so as to create a tax advantage by virtue of the normal treatment's reduction in the amounts taxable on the lessor.

The override (CTA 2010, s. 373–375; ITTOIA 2005, s. 148FC) applies where a person is or has been a lessor under a long funding lease of plant or machinery and each of three conditions is met.

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