It may be necessary to analyse the ‘lump sum’ payable by the lessee to the lessor between an adjustment to past revenue outgoings (which would itself be revenue) and the balance consisting of the ‘capital sum’ dealt with under the capital allowances code where:

leased plant or machinery takes the form of fixtures in a building,

the circumstances are those set out in CAA01/S177 (equipment lessors), see CA26200,

an election is made to ensure that the lessor obtains capital allowances (even though under general law he has no title to the asset),

the user negotiates his release from the agreement by the payment of a lump sum,

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