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HMRC internal manual

Corporate Finance Manual

Other tax rules on corporate finance: securitisation: periods beginning on or after 1 January 2005: the interim regime: application of former UK GAAP

The taxation of companies in the interim regime

The broad intention of the interim regime was to preserve the tax treatment of securitisation companies until the permanent regime could be introduced. Such companies are therefore taxed on the basis of UK GAAP as it stood at 31 December 2004 (‘old UK GAAP’), rather than the more volatile IAS to which they are subject in their commercial accounts. The tax issues set out in CFM72100 onwards continue to be relevant to such companies.

Where a securitisation company within the interim regime in FA05/S83 does not qualify for the permanent regime set out in the Taxation of Securitisation Companies Regulations 2006, or where it does elect into the permanent regime under Regulation 13 (CFM72330), it will continue to be taxed according to ‘old UK GAAP’, whatever the basis on which it draws up accounts. Further regulations applicable to securitisations other than those involving financial assets have been made (in the case of insurance) or will be made in due course.