CFM17520 - Repos: FA 2007 rules for companies: second tax consequence for debtor repos and debtor quasi-repos

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 repos and debtor quasi-repos: second tax consequence (Paragraph 5 Schedule 13 FA 2007)

The second tax consequence for debtor repos and debtor quasi-repos is that the whole arrangement is treated as a loan relationship ( CFM17522), and that the borrower obtains relief for any finance charge shown in its accounts that represents its cost of borrowing ( CFM17524).