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D7.215 Securitisation company in the permanent regime—tax treatment

For an overview of securitisation see D7.205 and for details of the interim regime see D7.210 onwards.

For HMRC guidance on the permanent regime, see CFM72300 onwards.

The permanent regime for securitisation companies is set out in CTA 2010 ss 623–625 (Pt 13, Ch 4) and in regulations¹. They apply with effect for periods of account beginning on or after 1 January 2007, unless the securitisation company is (or was) within the interim regime and has not opted into the permanent regime (see 'Election into the permanent regime or out of the interim regime' at D7.205)².

Under the permanent regime a company that meets the definition of a securitisation company (D7.218) and satisfies the relevant conditions (D7.219) is taxed on its retained profit rather than on the profit shown in its accounts (see below at 'Profit calculation for a securitisation company'). In addition the following specific provisions apply to securitisation companies:

1. Ìý

   •ÌýÌýÌýÌý deduction of tax at source – there is no obligation