‘Sideways relief’ (see ¶261-000) is not given to an individual for losses from ‘trade leasing allowances’ unless the individual carrying on the trade meets a time commitment test. The purpose of the rule is to deny the more generous reliefs available for trading losses if the transaction is, in reality, a form of investment rather than trading as such.
A ‘trade leasing allowance’ is a plant and machinery allowance (see, generally, ¶236-000ff.) in relation to expenditure that is incurred:
•on the provision of plant or machinery for leasing in the course of a trade; or