The following Tax guidance note provides comprehensive and up to date legal information covering:
This Practice Note considers the UK taxation treatment of securitisation companies that fall within the scope of the permanent securitisation regime. It explains:
what a securitisation is
that there are five types of securitisation company
the additional conditions that must be satisfied by any type of securitisation company in order for it to be taxed under the permanent securitisation regime, namely:
the unallowable purposes test, and
the payments condition
the UK corporation tax treatment that applies to securitisation companies that satisfy all the conditions to be taxed under the permanent securitisation regime
the consequences for a company of failing to fall within the permanent securitisation regime
the limited recourse nature of the notes issued in a securitisation
the interaction with the diverted profits tax, and
the stamp duty, stamp duty reserve tax (SDRT) and VAT treatment of the securitisation transaction
This Practice Note does not cover:
non-UK tax resident companies that are involved in a securitisation
the temporary securitisations regime, or
any transitional rules
This Practice Note focuses on the permanent securitisation regime as it applies to companies involved in an asset-backed securitisation, but the rules also apply to companies involved in other types of securitisation structures, such as whole business securitisations, provided all the conditions are satisfied for the regime to apply.
For a guide on what to include in a tax opinion
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