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Commentary

D9.1008 Tax treatment of lender under a creditor repo or creditor quasi-repo

Corporate tax

The lender under a creditor repo or creditor quasi-repo arrangement is not taxed on income arising on the securities during the period in which the repo agreement is in force1. A repo agreement is in force from the time the securities are originally sold to the time when the relevant repurchase takes place, or it becomes apparent that the repurchase will not take place2.

Tax relief is not available for manufactured payments made by the lender to the borrower.

This tax treatment applies provided no amounts of income or expenditure are required to be recognised in computing the lender's profits or losses of an accounting period under GAAP3.

Where

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