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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Other tax rules on corporate finance: securitisation: periods beginning on or after 1 January 2005: the interim regime: definitions

Types of securitisation company in the interim regime

Five categories of securitisation company are dealt with in FA05/S83. They have the same names as in the permanent regime, and are

  • a note-issuing company
  • an asset-holding company
  • an intermediate borrowing company
  • a warehouse company
  • a commercial paper funded company.

CFM72230 and CFM72240 has more on these categories.

The key requirement, that a company, must be party to a ‘capital market arrangement’ (CMA) (CFM72230), is the same in both the interim and permanent regimes. Any explanation of other terms used in the permanent regime (for example, the interpretation of ‘incidental activities’) may be taken to apply for the interim regime as it does for the permanent regime, unless otherwise specified.