Securitisation Companies Tax Regime


HM Treasury and HM Revenue & Customs are consulting on the reform of the taxation of securitisation companies, seeking views on the Stamp Duty loan capital exemption as it applies to securitisations and to insurance-linked securities.  

Current work:

The ACC and AIMA have submitted a response to this consultation, noting that the government should ensure that any changes that it implements to the corporation tax and stamp duty regime will:

  • Preserve the underlying principle which charges to corporation tax the retained profits of the securitisation company but provides tax neutrality for the investors in the notes that it issues;
  • Retain the ability of originators, managers, and investors to access the regime in a straightforward manner;
  • Continue to align the regime with existing and developing practices and processes; and
  • Be competitive with securitisation company structuring options available in other jurisdictions.

The full response is available for members to review here.  

Upcoming actions:

HMT and HMRC are considering consultation responses with a view to responding in due course.  

(Last updated: 29 June 2021)