Consultation outcome

Reform of the taxation of securitisation companies

• From: HM Revenue & Customs and HM Treasury
• Published: 23 March 2021
• Last updated: 30 November 2021 — See all updates

This was published under the 2019 to 2022 Johnson Conservative government

This consultation has concluded

Read the full outcome

Summary of responses (open document format)

ODT, 89.3 KB

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Summary of responses

PDF, 232 KB, 19 pages

Detail of outcome

The consultation sought views on making changes to clarify and/ or reform certain aspects of the taxation of securitisation companies and the Stamp Duty loan capital exemption as it applies to securitisations and to insurance-linked securities.

The consultation ran from 23 March 2021 to 3 June 2021: we received 15 written responses, and held a number of virtual meetings and calls during and after the consultation period. The government is grateful for the input.

The government is publishing 2 draft statutory instruments for technical consultation, together with accompanying draft explanatory memoranda and tax information and impact notes.

These reflect the decisions taken for 3 areas identified for consultation, as set out in the summary of responses.

The government will consult informally on the fourth area identified, the range of assets which may be securitised, as well as on related areas in the securitisation tax regime. This will be carried out in parallel with continued informal consultation in relation to the implication of holding land within securitisation companies.

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Original consultation

Summary

We are seeking views on the taxation of securitisation companies and on the Stamp Duty loan capital exemption as it applies to securitisations and to insurance-linked securities.

This consultation ran from
9:30am on 23 March 2021 to 11:45pm on 3 June 2021

Consultation description

This consultation seeks views on making changes to clarify and/or reform certain aspects of:

• the taxation of securitisation companies, as set out in the Taxation of Securitisation Companies Regulations (Statutory Instrument 2006/3296)
• the Stamp Duty loan capital exemption (section 79 Finance Act 1986) as it applies to securitisations and to insurance-linked securities

This consultation will be of particular interest to taxpayers, investors, advisers and tax professionals concerned with securitisations or insurance-linked securities.

Documents

Reform of taxation of securitisation companies

PDF, 243 KB, 20 pages

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Reform of taxation of securitisation companies (open document format)

ODT, 86.5 KB

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Published 23 March 2021
Last updated 30 November 2021 + show all updates

1. 30 November 2021

   Added summary of responses and outcome summary, including link to a technical consultation also published today (30 November 2021).

2. 23 March 2021

   First published.