Corporation Tax Act 2009 section 78

Repo transactions and stock lending arrangements before 1 October 2007

Section 78 provides transitional rules ensuring that repo transactions and stock lending arrangements already in force before 1 October 2007 continue to be taxed under the old rules, with updated cross-references to the Corporation Tax Act 2009.

• The new repo rules in Chapter 10 of Part 6 of the Corporation Tax Act 2009 do not apply to any arrangement that came into force before 1 October 2007.
• The old rule in paragraph 15 of Schedule 9 to the Finance Act 1996 continues to apply to pre-1 October 2007 repo arrangements, stock lending arrangements involving transfers of securities otherwise than by sale, and any other disposals before that date.
• Where the old rule continues to apply, references to the former loan relationships legislation in Chapter 2 of Part 4 of the Finance Act 1996 are replaced by references to Part 5 of the Corporation Tax Act 2009.
• Similarly, the specific reference to section 84 of the Finance Act 1996 within the old rule is replaced by a reference to section 304 of the Corporation Tax Act 2009.