The New Tax Regime for Securitisation Companies

In this article John Lindsay, Linklaters, considers the scope of the new regime for securitisation companies which has been introduced by the Taxation of Securitisation Companies Regulations 2006 (SI 2006/3296) and which applies for statutory accounting periods beginning on or after 1 January 2007.

John Lindsay, Linklaters

The reason why a special tax regime for securitisation companies has been introduced is due to accounting changes. The concern was that the introduction of international financial reporting standards (IFRS), and in particular IAS 39, which in turn has been incorporated into UK GAAP by FRS 26, could result in a distortion in the level of a securitisation company’s accounting and thus taxable profits.