Prior to the introduction of the long funding lease rules (see ¶1096-000ff.) with effect from 1 April 2006, the United Kingdom had specific provisions covering the availability of capital allowances on assets leased by a UK lessor to a non-UK lessee. These rules still apply in respect of leases finalised prior to 1 April 2006, but do not apply where the lease has been finalised on or after that date. Consequently, whilst the rules are of no consequence for new leases they remain relevant to a decreasing number of certain continuing transactions.

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