Part 11Manufactured payments and repos
Chapter 5Price differences under repos
Additional tax treatment
C1609Additional income tax consequences of price differences
1
Subsections (2) and (3) apply if an amount is treated under section 607 as a payment of interest.
2
If the repurchase price is more than the sale price, the repurchase price is treated for other income tax purposes as reduced by the amount of the payment of interest.
3
If the sale price is more than the repurchase price, the repurchase price is treated for other income tax purposes as increased by the amount of the payment of interest.
4
“Other income tax purposes” means income tax purposes other than the purposes of—
a
sections 601 to 605 (deemed manufactured payments: repos), and
b
this Chapter.
5
The Treasury may by regulations provide for any amount which is treated under section 607 as received as a payment of interest to be treated, in such circumstances and so far as may be described in the regulations, as exempt pension income.
6
“Exempt pension income” means income which is eligible for relief from income tax as a result of section 613(4) or 614(2), (3) or (4) of ICTA or section 186 of FA 2004 (exemptions about pensions and annuities).
7
Section 261G of TCGA 1992 deals with the effect on the repurchase price for capital gains tax purposes of an amount being treated under section 607 as a payment of interest.