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Commentary

D7.210 Securitisation companies in the interim regime

Corporate tax

D7.210 Securitisation companies in the interim regime

For an overview of securitisation see D7.205 and for details of the permanent regime see D7.215 onwards.

For HMRC guidance on the interim regime, see CFM72200 onwards.

Tax treatment of securitisation companies in the interim regime

Under the interim regime, securitisation companies (see below) are taxed as if their accounts were prepared under UK generally accepted accounting practice (GAAP) as it stood on 31 December 20041. This regime applied initially for periods of account beginning on or after 1 January 2005, and ending before 1 January 2008. Regulations extended the end date to 1 January 2017 and then further to 1 January 2037 for companies which2:

  1. Ìý

    •ÌýÌýÌýÌý were within the interim regime in relation to a period of account ending before 1 January 2008 and

  2. Ìý

    •ÌýÌýÌýÌý either:

    1. Ìý

      –ÌýÌýÌýÌý became party to a capital market arrangement for the purposes of the interim regime or a related transaction before 1st January 2008 and continues to be party to that arrangement or transaction,

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