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HMRC internal manual

Corporate Finance Manual

Deemed loan relationships: repos: tax rules: definitions


The rules in CTA09/PT6/CH10 identify four types of repo transactions

As repos are deemed to be loan relationships, terms used in the rules in CTA09/PT5 apply to repos. In addition, there are a number of general provisions and definitions for the repo rules set out at CTA09/S552 to S559.


‘Securities means shares, stock or securities issued by the UK Government, or UK public or local authorities, UK companies, or overseas securities. Securities are ‘similar’ if they entitle their holders to the same rights against the same persons as to capital, interest and dividends, and to the same remedies for the enforcement of those rights.


If accounts have not been drawn up in accordance with GAAP, the requirement in CTA09/S309 provides that they will be treated as if they had been.

An amount is ‘recognised in determining a company’s profit or loss’ if it is recognised for accounting purposes:

  • in its profit and loss account or income statement;
  • in its statement of recognised gains and losses or statement of changes in equity; or
  • in any other statement of items brought into account in calculating its profits and losses.