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HMRC internal manual

Corporate Finance Manual

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HM Revenue & Customs
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Deemed loan relationships: repos: tax rules: creditor and creditor quasi-repos: further examples: creditor quasi-repo

Example: creditor quasi-repos

CFM46250 explains why both C and D have a creditor quasi-repo in this case.

  • 1/1/09: A sells securities to C for 100.
  • 30/4/09: C novates its rights and obligations under the repo to D (also a lender), for which it receives 102 from D. This represents the advance of 100 made by C, plus a finance return of 2 (4 months at 6% per annum).
  • 30/6/09: A purchases the same or similar securities from D for 103. This includes a further finance return of 1 (2 months at 6% per annum).

Treatment of C

Accounting entries, in accordance with GAAP in addition to the entries at CFM46250:  
   
1/1/09-30/4/09 (repo ‘interest’ accrual): Dr Financial Asset 2; Cr P&L 2 (the financial asset which has increased to 102 is reduced to nil by receipt of the novation payment on 30/4/09)
Net Profit and Loss result: Credit 2: ‘interest’

Tax Treatment

C’s finance return of 2 is treated as interest for loan relationships purposes (CFM46270).

Treatment of D

Accounting entries, in accordance with GAAP in addition to the entries at CFM46240:  
   
30/4-30/6/09 (repo ‘interest’ accrual): Dr Financial Asset 1; Cr P&L 1 (the financial asset which has increased to 103 is reduced to nil by receipt of the repurchase price on 30/6/09)
Net Profit and Loss result: Credit 1: ‘interest’

Tax Treatment

D’s finance return of 1 is treated as interest for loan relationships purposes (CFM46270).

Further point to note

This transaction corresponds to the debtor repo example referred to in the footnote to CFM46430 (if A is a company).