Should corporate income tax be charged on special terms when transferring equipment to a gig specialist?

For a Diya City resident who has chosen to pay corporate income tax on special conditions, the cost of equipment transferred to a gig specialist as a tool (means) for performing work (providing services) without transferring ownership of such equipment (provides for its return), in particular, if such transfer in favor of a gig specialist is made under a loan agreement for fixed-term use, as well as the cost of equipment rental services without making claims for compensation of its cost by a gig specialist (free of charge), shall not be included