CFM17530a - Repos: FA 2007 rules for companies: creditor repo example

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

Creditor repo: example

Transaction


  • 1/1/09: A (borrower) sells securities to C (lender) for 100.
  • 30/6/09: A repurchases the same or similar securities from C for 103, agreed at the outset (this includes a finance return of 3: see CFM17550a).
C’s accounting entries, in accordance with GAAP
1/1/09 (making of advance):Dr Financial Asset 100; Cr Cash 100
30/6/09 (repayment of advance):Dr Cash 103; Cr Financial Asset 103


C has a creditor repo because all of the conditions in CFM17530 are met:

Condition A: A receives an advance of money from C. Condition B: in accordance with GAAP, C records a financial asset in respect of that advance. Condition C: A sells securities to C. Condition D: C is entitled or obliged to sell those or similar securities. Condition E: in accordance with GAAP, the selling of those securities extinguishes C’s financial asset in respect of the advance. Further points to note


  • This transaction corresponds to the debtor repo example at CFM17508a (where A is a company).
  • C also has a creditor repo if, under the arrangement, it sells the securities to another person (“B”) instead of to A. Such a transaction corresponds to the debtor quasi-repo example at CFM17512a (where A and B are companies).