Corporate tax leasing, one of the most controversial sections of the 1981 tax act, provides hardly any benefit to small business, and those that sold their tax breaks got far less than big sellers, according to a study by the Joint Committee on Taxation.

The 48-page analysis released yesterday in preparation for reconsideration in Congress of the leasing provisions made these points:

* Some highly profitable and taxpaying companies, particularly those producing oil and coal, are selling their tax breaks on new investments to be able to capitalize on other tax provisions, particularly percentage depletion and intangible drilling-cost deductions. Although corporate tax sales were designed to help beleaguered firms, such highly profitable industries as petroleum and chemicals are among the major beneficiaries of the legislation.

* The revenue losses will be higher than originally anticipated by the Treasury Department. Last year, the Treasury estimated that corporate tax sales through leases would result in the loss of $26.9 billion through 1986. The Joint Committee contended the figure would be $29.5 billion.

* Exemptions in the law allow the benefits of corporate tax leasing to be used by foreign corporations and governments that pay no U.S. taxes, despite the fact that the goal was to encourage domestic investment--in effect, a subsidy.

The key argument in favor of corporate tax leasing is that it would create a "level playing field," eliminating tax advantages available to profit-making companies that are unavailable to companies that pay no taxes. If a firm pays no taxes, accelerated depreciation and investment-tax-credit benefits are useless.

The Joint Committee found that for firms that expect to pay taxes in the near future, this argument has some validity. For the firm expecting to pay no taxes for a long time, however, the ability to sell useless tax breaks makes it possible to make investments that, for other companies, would be rejected because the profits would be inadequate.

"The nontaxable firm can pay $100 to buy assets expected to return as little as $88 and still earn its 10 percent rate of return [from the sale of tax benefits]. To the extent that capital is diverted from assets that will earn $110 [the amount required to justify an investment for a profitable company] to ones that will earn only $88, economic growth will suffer," the committee staff said.

The conclusion that small businesses do not benefit from corporate tax leasing can be drawn from figures describing the "efficiency" of different-sized transactions.

Tax sales on assets worth $100,000 or less amounted to just 6 percent of the total volume. In addition, for the companies selling the tax breaks on these assets, 61.7 cents was returned on the dollar, while the companies buying the tax breaks got 33.9 cents and middlemen got 4.4 cents.