Changes to the securitisation tax regime

John Lindsay, Linklaters LLP, considers the changes to the permanent regime and the temporary regime for securitisation companies that were introduced by statutory instrument in December 2007.

Changes to the permanent regime

A permanent regime was introduced for the taxation of securitisation companies by the Taxation of Securitisation Companies Regulations 2006 (the Regulations). The Regulations apply to securitisation companies that meet the conditions set out therein for accounting periods beginning on or after 1 January 2007. The amendments that are discussed below were introduced by SI 2007/3339 and, subject to one exception that is considered below, took effect for accounting periods beginning on or after 1 January 2007 and which were still current at 3 December 2007.