CFM17508a - Repos: FA 2007 rules for companies: debtor 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

Debtor repo: example

Transaction

  • 1/1/09: The borrower (A) sells securities to the lender (C), for which it receives an advance of 100.
  • 30/6/09: A repurchases the same or similar securities from C for 103, agreed at the outset (this includes a finance charge of 3: see CFM17528a).
A’s accounting entries, in accordance with GAAP
1/1/09 (receipt of advance):Dr Cash 100; Cr Financial Liability 100
30/6/09 (repayment of advance):Dr Financial Liability 103; Cr Cash 103


A has a debtor repo because all of the conditions in CFM17508 are met:

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


  • This example corresponds to the creditor repo example at CFM17530a (where C is a company).
  • A also has a debtor repo if, under the arrangement, it purchases the securities from another person (“D”) instead of repurchasing them from C. Such a transaction corresponds to the creditor quasi-repo example at CFM17534a (where C and D are companies).