CFM17562 - Repos: FA 2007 rules for companies: interaction with “shares as debt” rules

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

Interaction with “shares as debt” rules in sections 91A-G FA 1996

No double taxation

Where a lender in a creditor repo or creditor quasi-repo is taxable on its finance return under paragraph 10 Schedule 13 FA 2007, it is not also taxable under the “shares as debt” rules in sections 91A-G FA 1996.