How Japanese operating leases actually work
A practitioner's guide to JOL and JOLCO for aircraft, ships and containers: the structure, the tax rules behind it, what makes a deal work, and what to check. Written by an arranger, shared on request.
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Japanese investors
equity via TK
Bank
non-recourse loan
Lessor (SPC)
owns the asset
Airline or
ship operator
equity
loan
lease
rent
purchase option
The basic JOLCO structure. The guide walks through each flow and the rules that apply to it.
What the guide covers
Structure and parties Investors, the TK lessor, lender and lessee, and how JOL differs from JOLCO.
Why it works for each side Where the lessee's cost saving and the investor's tax deferral come from.
Depreciation rules Japanese useful lives and 200% declining balance, plus used assets and the simplified method.
Lease classification The Japanese tax tests, the new lease accounting standard and the lender's full-payout requirement.
Term and purchase option How the lender, tax and investor conditions fit together.
Ships and containers Flag and ship type, special depreciation and the 2023 and 2026 changes for TK structures, and container sale-leasebacks.
Case law and reform history The 2005 aircraft lease cases, the 2015 Supreme Court ruling and the main tax reforms.
Risks and checklist The points investors, lessees and arrangers should confirm on each deal.
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The guide is general information based on public sources. It is not tax, legal, accounting or investment advice, and it is not an offer or solicitation for any investment product. Japanese tax treatment depends on the facts of each transaction.
Your name, company and position are used only to decide on access and are not shared.