Income Tax Act 2007 section 925F

Interpretation of the repo sections

Section 925F defines the key terms and rules of interpretation that apply to the repo provisions in sections 925A to 925E, covering what counts as an arrangement, what securities are, when securities are similar, and how beneficial ownership determines who is treated as buying or selling.

• An "arrangement" includes any agreement or understanding, whether or not it is legally enforceable, and any conditions attached to a right or obligation to buy securities are disregarded
• "Securities" covers shares, stock or other securities issued by any government, public or local authority, company or other body, whether based in the United Kingdom or overseas
• Securities are treated as "similar" if they confer the same rights to capital, interest and dividends against the same persons, with the same remedies, regardless of differences in nominal amount, form or method of transfer
• Where securities are bought or sold by one person but held for the benefit of another, the beneficial owner is treated as the buyer or seller for the purposes of the repo rules