Commentary

D7.1301 Securitisation companies—tax treatment

Corporate tax
Corporate tax | Commentary

D7.1301 Securitisation companies—tax treatment

Corporate tax | Commentary

Division D7.13     Securitisation companies

For updates affecting this Division please see Part D0 Updates

Overview of securitisation regime

D7.1301 Securitisation companies—tax treatment

For the latest New Development, see ND.1936.

There is a useful summary of what constitutes 'securitisation' in HMRC's internal guidance1. Most commonly, securitisation involves a company with debt assets generating a flow of income using that flow of income to back the issue of further securities. Credit card companies and mortgage companies, for example, make use of securitisation arrangements of this kind. However, as HMRC point out, securitisation is not limited to debts. Wherever there is a fairly certain stream of income, it may be possible to securitise it. Accordingly, a landlord with a stream of rental income might be able to issue marketable securities backed by the income stream from the rented properties. A pop star about to embark on a world tour might be able to issue

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