Corporation Tax Act 2010 section 623

Meaning of "securitisation company"

Section 623 defines what qualifies as a "securitisation company" for the purposes of the corporation tax rules in this chapter.

  • A company qualifies if it is a debtor in a capital market investment, securities representing that investment have been issued, and the investment forms part of a capital market arrangement
  • The company must also satisfy any additional conditions specified by the Treasury in regulations (currently set out in regulation 4 of the Taxation of Securitisation Companies Regulations 2006, SI 2006/3296)
  • A company can also qualify as a securitisation company if it has a direct or indirect relationship (of a type specified by Treasury regulations) with another company that meets the above criteria
  • The terms "capital market investment" and "capital market arrangement" take their meaning from section 72B(1) and Schedule 2A of the Insolvency Act 1986

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