CFM17500 – Repos: FA 2007 rules for companies: overview and contents

This guidance describes the corporation tax treatment of sale and repurchase arrangements (“repos”) where the initial sale of securities takes place on or after 1 October 2007

Overview, commencement date and contents

Schedules 13 and 14 of Finance Act 2007 introduced a new corporation tax regime for arrangements for the sale and repurchase of securities (“repos”).

The provisions of Schedule 13 apply to arrangements that come into force on or after 1 October 2007. Arrangements come into force from the time when the securities are initially sold. This commencement date is provided by The Finance Act 2007 (Schedules 13 and 14) Order 2007 (SI 2007/2483).

Where either of the parties to a repo is within the charge to income tax and capital gains tax, the rules at CFM17200+ will continue to apply to that taxpayer.


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