This Practice Note on Islamic finance and tax outlines how sukuk al ijara (sale and leaseback) over land in England works as a form of financing, and introduces the UK tax reliefs that are available under Schedule 61 to the Finance Act 2009 to such arrangements that qualify as alternative finance investment bond (AFIB) arrangements for UK tax purposes. Sukuk (singular form: ‘sakk’) is a type of Shari’a financing arrangement also referred to as Islamic bonds or certificates. For more information, see Practice Notes: The structure and elements of a Sukuk transaction and Sukuk—investment bond arrangements and their UK direct tax treatment—What are sukuk? Sukuk may benefit from the UK tax treatment provided to alternative finance investment bond (AFIB) arrangements if all the statutory conditions are met. For more information on those rules, see Practice Note: Sukuk—investment bond arrangements and their UK direct tax treatment. Sukuk al ijara is a particular form of sukuk. Under a sukuk al ijara, the asset held by the bond-issuer (the

This Practice Note provides an overview of the key considerations that an Obligor should take into account in selecting an appropriate structure for the issuance of Sukuk, the main documentation relating to the key structures and the key terms that would be incorporated into such documentation. This Practice Note also sets out the drivers behind the dominance of the Sukuk market in recent years and the legislative developments that have contributed to such growth in the market. For further information on Sukuk transactions and the background to the transaction structures set out below, see Practice Note: The structure and elements of a Sukuk transaction. Form of transactions Sukuk instruments are instruments that enable holders to take direct or indirect ownership of an underlying asset or pool of assets and not have to pay interest. They have been defined by the Accounting and Auditing Organisation for Islamic Finance Institutions (AAOIFI) as representing individual shares in ownership of tangible assets, usufruct and services or in the ownership of the assets of particular projects or

FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: Stamp duty and SDRT will, in 2027, be replaced with a single, self-assessed tax on transfers of securities, the securities transfer tax (STT) (formerly referred to as the securities transfer charge or STC), that will be paid (and reported) through electronic transfer systems such as CREST or, where appropriate, a new online portal. Draft legislation for the STT was published on 13 July 2026, along with explanatory notes, a policy paper and the outcome of the higher rate 1.5% stamp tax consultation. Subject to exemptions, the STT draft legislation includes a main charge of 0.5% for agreements to transfer chargeable securities to another person for consideration in money or money’s worth and, for transfers to a clearance service (CS) or depositary receipt issuer (DRI), a higher-rate charge of 1.5%. The main charge arises when an agreement is made or, in the case of a conditional agreement, when the conditions are satisfied, although, where

This Practice Note outlines the UK VAT treatment of the issue of a sakk by an issuer to an investor (or sakk holder). A sakk is a certificate that confers certain rights on the holder to receive payments from time to time. Its key characteristics are comparable to those of a bond (or similar financial instrument). ‘Sukuk’ is the plural of ‘sakk’. A sukuk issuance is a form of Islamic financing. For more information on Islamic financing generally, see Practice Note: Key principles of Islamic finance. For more information on other (non-VAT) tax aspects of sukuk, see Practice Notes: Sukuk—investment bond arrangements and their UK direct tax treatment, Sukuk—investment bond arrangements and stamp duty and SDRT and Sukuk al ijara—tax reliefs for sale and leaseback arrangements. This Practice Note is written on the assumption that: • the issuer is a corporate special purpose vehicle • both the issuer and the sakk holder belong in the UK for VAT purposes in relation to the sukuk issuance • any trust property

This Practice Note on Islamic finance and tax considers the UK corporation tax and withholding tax issues relevant to sukuk (certificates) that qualify as investment bond arrangements and are issued as part of alternative finance investment bond or AFIB arrangements. Shari’a-compliant financing arrangements (also known as Islamic financing arrangements) can take a number of forms. The UK has introduced specific provisions known as the alternative finance arrangement rules to deal with the direct tax treatment of certain forms of Shari’a financing. The UK alternative finance arrangement rules are intended to allow Shari’a-compliant financing arrangements to be treated for UK direct tax purposes in the same way as an equivalent conventional financing arrangement. This treatment is dependent on the financing arrangements satisfying the relevant conditions set out in the legislation applicable to alternative finance arrangements. The rules currently cover five different types of financing arrangements. The direct tax rules for alternative finance arrangements are not restricted to Islamic financing. Non-Shari’a arrangements could potentially fall within the scope of

In a life assurance policy (for example, whole of life assurance or endowment assurance), the sum assured is the minimum amount payable to the assured or his/her dependants on the death of the life assured.

Part of a prospectus which summarises certain key information about the company, the securities and the offer. The contents and layout of the summary are prescribed by Article 7 of the UK Prospectus Regulation (Retained Regulation (EU) 2017/1129). See also PRR 2.2.4.

A criminal offence which is normally tried in a magistrates’ court and which is generally considered to be less serious than other types of offences. The sentencing powers for summary only matters are more limited although there are some which are punishable by way of imprisonment and/or unlimited fines. There are also time limits for commencing summary only proceedings.

A judicial office created by Courts Reform (Scotland) Act 2014 following Scottish Civil Courts Review, which reported in 2009.

The procedure by which a court, when making an order about costs, orders a party to pay a determined amount of money rather than fixed costs or costs subject to detailed assessment.

Archived: This Practice Note is based on provisions revoked on 1 April 2013. It is therefore for historical purposes only. What is summary assessment? Summary assessment is the procedure used to assess the costs of an application at the hearing of that application (old rule 43.3). The usual order will be that these costs are payable within 14 days, but the court can vary the time period. For further guidance, see the Guide to the Summary Assessment of Costs published by the Senior Courts Costs Office. The general rule under old practice direction 44, para 13.2 is that the court should order summary assessment of costs: • at the end of a fast track trial • at the end of a hearing of not more than one day. If the hearing disposes of the whole action the costs order may deal with the costs of the whole claim • in certain Court of Appeal hearings However, the court will only order summary assessment of costs when a party seeks its

ARCHIVED: This Practice Note details the summary assessment bill of costs pilot scheme which was implemented between 1 April 2019 and 31 March 2022. It is therefore for historical purposes only. This Practice Note summarises the background to and detail of the two-year voluntary pilot operating in summary assessment proceedings (summary assessment statement of costs pilot scheme or statement of costs for summary assessment) introduced by CPR PD 51X, and operating between 1 April 2019 and 31 March 2022. It covers the background to the summary assessment statement of costs pilot under CPR PD 51X with reference to the electronic bill of costs which is mandatory for detailed assessment proceedings. It also covers the timing of the pilot and explains that it will apply to all claims in which costs are summarily assessed between 1 April 2019 and 31 March 2022. It introduces court forms N260A and N260B, appended to CPR PD 51X, which are to be used in the pilot scheme and which provide