The following Tax practice 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 on an asset-backed
**Trials are provided to all LexisPSL and LexisLibrary content, excluding Practice Compliance, Practice Management and Risk and Compliance, subscription packages are tailored to your specific needs. To discuss trialling these LexisPSL services please email customer service via our online form. Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason. Trial includes one question to LexisAsk during the length of the trial.
To view the latest version of this document and thousands of others like it, sign-in to LexisPSL or register for a free trial.
Existing user? Sign-in
Take a free trial
This Practice Note considers proprietary estoppel from a generic standpoint.For industry specific guidance on proprietary estoppel, see Practice Notes:•Estoppel and property law•Mortgages by estoppelProprietary estoppel—what is it?Unlike the other forms of estoppel (see Practice Note: Estoppel—what,
This Practice Note looks at CE-File electronic working in the courts under CPR PD 51O, in the context of case management. It provides guidance on how to file a document electronically, deal with rejected electronic filings, issue a claim electronically, file electronic bundles (eBundles) for case
This Practice Note considers the doctrine of forum non conveniens, also referred to as the appropriate forum or the proper place for a dispute to be determined. This doctrine is of relevance when determining whether the courts of England and Wales have jurisdiction to hear a dispute and is applied
Disposal and devolutionThe equity of redemption arises as soon as the mortgage is made. It is an interest in the land which the mortgagor can:•transfer, lease or mortgage inter vivos, or•by will (it passes on intestacy)No cloggingIt is a fundamental principle of a mortgage that there must be no clog
0330 161 1234
To view our latest legal guidance content,sign-in to Lexis®PSL or register for a free trial.