Taxation (International and Other Provisions) Act 2010 section 259NEZA

Securitisation companies

Section 259NEZA provides that securitisation companies are excluded from the hybrid mismatch rules contained in Part 6A of the Act.

• Securitisation companies are carved out from the hybrid mismatch provisions in Part 6A of TIOPA 2010.
• Any adjustment that would otherwise be required under the hybrid mismatch rules is treated as having no effect for a securitisation company.
• A securitisation company is one to which the Taxation of Securitisation Companies Regulations 2006 apply.
• This provision was introduced by Finance Act 2021 and ensures that the special tax regime for securitisation vehicles is not disrupted by the hybrid mismatch rules.