Commentary

D9.431 Stock lending, repos etc

Corporate tax
Corporate tax | Commentary

D9.431 Stock lending, repos etc

Corporate tax | Commentary

D9.431 Stock lending, repos etc

Stock lending

The accrued income provisions do not apply to stock-lending arrangements that are exempt from capital gains tax under TCGA 1992, s 263B(2)1. The income tax treatment of such arrangements is described in Division D9.6.

Repos

In a sale and repurchase arrangement (a repo), the original owner of the securities is taxed in respect of interest arising between sale and repurchase under provisions described in Division D9.7.

The general rule is that the accrued income provisions do not apply to the initial transfer of the securities or the transfer-back of the securities that concludes the arrangements.

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