CFM20000 - Securitisation: overview

Overview

The Oxford English Dictionary (Compact Edition) defines ‘securitisation’ as ‘the conversion of an asset, especially a loan, into marketable securities, typically for raising cash.’ Securitisation is widely used because of the advantages it offers in terms of management of risk and raising funds. See CFM3304.

This guidance is about securitisation arrangements using ‘Special Purpose Vehicles’ (SPVs).

Contents

Background

CFM20010Securitisation: background
CFM20020Securitisation: basic terminology
CFM20030Securitisation: basic structures: true sale/asset-backed securitisation
CFM20030aSecuritisation: basic structures: example of a true sale/asset-backed securitisation
CFM20035Securitisation: basic structures: master trust securitisation
CFM20035aSecuritisation: basic structures: example of a master trust structure
CFM20040Securitisation: other types of securitisation
CFM20040aSecuritisation: other types of securitisation: example of a synthetic securitisation
CFM20050Securitisation: other common features

Taxation: periods beginning before 1 January 2005

CFM20060Securitisation: taxation: periods beginning before 1 January 2005
CFM20070Securitisation: taxation: periods beginning before 1 January 2005: general points
CFM20080Securitisation: taxation: periods beginning before 1 January 2005: bad and doubtful debts
CFM20090Securitisation: taxation: periods beginning before 1 January 2005: offshore SPVs
CFM20100Securitisation: taxation: periods beginning before 1 January 2005: example

Taxation: periods beginning on or after 1 January 2005

CFM20200Securitisation: taxation: periods beginning on or after 1 January 2005: overview of the new rules
CFM20210Securitisation: taxation: periods beginning on or after 1 January 2005: the interim regime
CFM20220Securitisation: taxation: periods beginning on or after 1 January 2005: the interim regime: definitions
CFM20230Securitisation: taxation: periods beginning on or after 1 January 2005: the interim regime: the note-issuing company
CFM20240Securitisation: taxation: periods beginning on or after 1 January 2005: the interim regime: other types of securitisation company
CFM20250Securitisation: taxation: periods beginning on or after 1 January 2005: the interim regime: the application of ‘former UK GAAP’
CFM20260Securitisation: taxation: periods beginning on or after 1 January 2005: the interim regime: continuation after 2008
CFM20270Securitisation: taxation: periods beginning on or after 1 January 2005: the interim regime: continuation after 2008: the transitional rules

Taxation: periods beginning on or after 1 January 2007

CFM20310Securitisation: taxation: periods beginning on or after 1 January 2007: the permanent regime
CFM20315Securitisation: taxation: periods beginning on or after 1 January 2007: : alternative finance arrangements
CFM20320Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations
CFM20330Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: commencement
CFM20340Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: interpretation
CFM20350Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: interpretation: ‘financial assets’
CFM20360Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: scope
CFM20370Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: meaning of ‘securitisation company’
CFM20380Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the note-issuing company
CFM20390Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the note-issuing company: ‘independent persons’
CFM20400Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the note issuing company: incidental activities
CFM20410Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the asset-holding company
CFM20420Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the asset-holding company: partnerships
CFM20430Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the asset-holding company: subordinated debt
CFM20440Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: intermediate borrowing companies
CFM20450Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: warehouse companies
CFM20455Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: warehouse companies: abortive warehouse arrangements
CFM20460Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: commercial paper funded companies
CFM20470Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: ‘retained profit’
CFM20475Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: ‘retained profit’: dividends received
CFM20480Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: conditions to be met by securitisation companies
CFM20490Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the payments condition: introduction
CFM20500Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the payments condition: the formula
CFM20510Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the payments condition: examples of ‘RA’
CFM20520Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the payments condition: meaning of payment
CFM20530Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the payments condition: failure to make a payment
CFM20535Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the payments condition: other points
CFM20540Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the unallowable purposes rule
CFM20550Securitisation: taxation: periods beginning on or after 1 January 2007 the regulations: the corporation tax charge: the formula: “RP” and “DS”
CFM20555Securitisation: taxation: periods beginning on or after 1 January 2007 the regulations: the corporation tax charge: the formula: “D”
CFM20560Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: the ‘specified amount’
CFM20570Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: applies instead of the normal CT rules
CFM20580Securitisation: taxation: periods ending on or after 1 January 2007: the regulations: modifications to the commencement and cessation rules
CFM20590Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules
CFM20600Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: group relief
CFM20610Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: capital assets
CFM20620Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: loan relationships
CFM20630Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: derivative contracts
CFM20640Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: other points
CFM20645Securitisation: taxation: periods beginning on or after 1 January 2007: credit card securitisations
CFM20650Securitisation: taxation: periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: taxation of the investor
CFM20660Securitisation: taxation: periods beginning on or after 1 January 2007: other types of securitisation company

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