CFM17230 - Repos: taxation: redemption or substitution of securities during repo

This guidance describes the treatment of repos for income tax and capital gains tax purposes, and for corporation tax purposes where the original owner transfers the securities to the interim holder before 1 October 2007

The tax consequences on a redemption or substitution of securities during repo

Securities that are the subject of the repo may be redeemed during the life of the repo, so that it is the proceeds of redemption that are returned, not the securities themselves. Section 730A, or as the case may be, ITA07/S607 also applies in these circumstances, see SI1995/3220.

It is quite common for repo agreements to enable the securities originally sold under the repo to be replaced with other securities of comparable credit risk quality and equal value. For the purposes of section 730A and Chapter 5 of Part 11 of ITA07 references to securities are to be taken to include references to securities which have been substituted for those originally sold.