290-800 Income tax restrictions on sideways relief for certain capital allowances
Trade leasing allowances
‘Sideways relief’ 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 in relation to expenditure that is incurred:
•on the provision of plant or machinery for leasing in the course of a trade; or