Part 6Relationships treated as loan relationships etc

Chapter 10Repos

Introduction

542Introduction to Chapter

1

The purpose of this Chapter is to secure that in the case of an arrangement—

a

which involves the sale of securities and the subsequent purchase of those or similar securities, and

b

which equates, in substance, to a transaction for the lending of money at interest from or to a company, with the securities which were sold as collateral for the loan,

the charge to corporation tax reflects the fact that the arrangement equates, in substance, to such a transaction.

2

Sections 543 to F1546 make provision about arrangements which are creditor repos or creditor quasi-repos.

3

Sections 548 to 551 make provision about arrangements which are debtor repos or debtor quasi-repos.