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HMRC internal manual

Corporate Finance Manual

Other tax rules on corporate finance: securitisation: periods beginning on or after 1 January 2007: other types of securitisation company

Other types of securitisation company

The Taxation of Securitisation Companies Regulations 2006 apply to companies involved in the securitisation of financial assets. Other regulations have been or will be made in relation to other types of securitisation.

Insurance securitisations

The Taxation of Insurance Securitisation Companies Regulations 2007 (SI2007/3402) apply with effect from periods of account beginning on 1 January 2007 and current on 3 December 2007. The regulations ensure that an ‘insurance special purpose vehicle’ (ISPV), as defined by Financial Services Authority rules, which is part of a capital market arrangement, is taxed on a similar basis to a securitisation company within the 2006 regulations. See the Life Assurance Manual and the General Insurance Manual for more details.

Real estate securitisations

It is intended to make regulations in due course to apply to companies involved in the securitisation of land and property assets. Guidance will be published when such regulations have been laid.