CFM17075 - Stock loans: tax issues

Taxation of stock loans

Stock lending gives rise to a number of tax problems, for instance:

• the temporary transfers of securities between lender and borrower would, in the absence of specific legislation, constitute disposals for capital gains CFM17080.
• the disposals and acquisitions would, in the case of an asset representing a loan relationship, constitute loan relationship related transactions ( CFM17265 and CFM17095).