The Taxation of Securitisation Companies (Amendment) Regulations, SI 2018/143, make changes to clarify four specific areas of uncertainty relating to the tax treatment of securitisation companies, for periods of account beginning on or after 1 January 2018.
The changes:
remove the withholding tax obligation on annual payments;
revise the definition of ‘financial assets’ (for arrangements made after 6 February 2018);
exclude securitisation companies from the recovery of unpaid corporation tax provisions; and
revise the definition of a ‘warehouse company’.
HMRC consulted on a draft version during December and January. The changes only apply to securitisation companies within the ‘permanent regime’ introduced in 2006, and not to those within the ‘interim regime’ who continue to use old UK GAAP.
The Taxation of Securitisation Companies (Amendment) Regulations, SI 2018/143, make changes to clarify four specific areas of uncertainty relating to the tax treatment of securitisation companies, for periods of account beginning on or after 1 January 2018.
The changes:
remove the withholding tax obligation on annual payments;
revise the definition of ‘financial assets’ (for arrangements made after 6 February 2018);
exclude securitisation companies from the recovery of unpaid corporation tax provisions; and
revise the definition of a ‘warehouse company’.
HMRC consulted on a draft version during December and January. The changes only apply to securitisation companies within the ‘permanent regime’ introduced in 2006, and not to those within the ‘interim regime’ who continue to use old UK GAAP.
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