CFM17050 - Stock loans

Overview and contents

This sections deals with what is meant by a stock loan, why companies use them and how they are taxed.

Contents

CFM17055Stock loans: background
CFM17060Stock loans: lenders
CFM17065Stock loans: legal form of stock loan
CFM17070Stock loans: collateral arrangements
CFM17075Stock loans: tax issues
CFM17080Stock loans: capital gains – acquisition and disposal under stock loan
CFM17085Stock loans: capital gains – disposal of borrowed shares during stock loan
CFM17090Stock loans: capital gains – default or redemption of securities
CFM17095Stock loans: loan relationships
CFM17100Stock loans: accrued income scheme
CFM17105Stock loans: anti-avoidance - deemed manufactured payments to lender where there is no provision for borrower to make payments representing dividends or interest income to lender
CFM17110Stock loans: anti-avoidance - deemed payment of interest on cash collateral where no interest is paid, or interest paid is not at a reasonably comparable deposit rate
CFM17115Stock loans: anti-avoidance – quasi-stock lending arrangements and quasi-cash collateral

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