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HMRC internal manual

Corporate Finance Manual

From
HM Revenue & Customs
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Other tax rules on corporate finance: securitisation: periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: the ‘specified amount’

The ‘specified amount’ under Regulation 14(3)

There is one further amount that may be added to the corporation tax charge. CFM72660 explains that the loan relationship and derivative contracts rules are amended so that any profit or loss on the disposal of a loan relationship or derivative contract intra-group is taxed on the originator company where the disposal is to a securitisation company. This is achieved by disapplying the rules in CTA09/PT5/CH4 and CTA09/PT7/CH5.

Where such a transfer took place before the commencement of the securitisation regime, CTA09/PT5/CH4 or FA02/SCH26/PARA28 may have already applied on a disposal to a securitisation company. An ‘exit charge’ under CTA09/S344 - S346 or CTA09/S630 - 632 may therefore arise on the securitisation company in respect of one of these disposals. This rule therefore ensures that any charge under CTA09/S344 or CTA09/S630 is added to the taxable profits calculated under Regulation 14.