BLM80376 | Sale of lessor companies and similar arrangements: change of ownership: exceptions to qualifying change of ownership: election out of charge: outline of restrictions
From HM Revenue & Customs · Business Leasing Manual
Sections 398D to 398E CTA2010
This guidance applies where the relevant day falls on or after 5 December 2009 and before 23 March 2011.
The restrictions imposed by an election out of the charge cover the following areas:
Set off of losses against profits of the company
Availability of capital allowances
Entry into the tonnage tax regime
Disposal values when plant or machinery is transferred out of the company.