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Contents

Official guidance
Corporate Finance Manual

CFM46000 · Deemed loan relationships: manufactured interest and repos

  • CFM46010 · Overview
  • CFM46050 · Deemed loan relationships: manufactured interest
  • CFM46060 · Deemed loan relationships: manufactured interest: DCC Holdings
  • CFM46070 · Deemed loan relationships: manufactured interest: DCC Holdings: FA 2009 changes
  • CFM46100 · Deemed loan relationships: repos: what is a repo?
  • CFM46110 · Deemed loan relationships: repos: general collateral repos
  • CFM46120 · Deemed loan relationships: repos: general collateral repos: examples
  • CFM46130 · Deemed loan relationships: repos: special collateral repos and reverse repos
  • CFM46200 · Deemed loan relationships: repos: tax rules: main features
  • CFM46210 · Deemed loan relationships: repos: tax rules: definitions
  • CFM46220 · Deemed loan relationships: repos: tax rules: creditor repos and creditor-quasi-repos
  • CFM46230 · Deemed loan relationships: repos: tax rules: creditor repos
  • CFM46240 · Deemed loan relationships: repos: tax rules: creditor quasi-repos
  • CFM46250 · Deemed loan relationships: repos: tax rules: creditor quasi-repos: examples
  • CFM46260 · Deemed loan relationships: repos: tax rules: creditor quasi-repos: first tax consequence
  • CFM46270 · Deemed loan relationships: repos: tax rules: creditor quasi-repos: second tax consequence
  • CFM46280 · Deemed loan relationships: repos: tax rules: creditor and creditor quasi-repos: ‘quasi-interest’ avoidance schemes
  • CFM46290 · Deemed loan relationships: repos: tax rules: creditor and creditor quasi-repos: further examples
  • CFM46300 · Deemed loan relationships: repos: tax rules: creditor and creditor quasi-repos: further examples: no income
  • CFM46310 · Deemed loan relationships: repos: tax rules: creditor and creditor quasi-repos: further examples: gross-paying
  • CFM46320 · Deemed loan relationships: repos: tax rules: creditor and creditor quasi-repos: further examples: net-paying
  • CFM46330 · Deemed loan relationships: repos: tax rules: creditor and creditor quasi-repos: further examples: creditor quasi-repo
  • CFM46340 · Deemed loan relationships: repos: tax rules: debtor and debtor quasi-repos
  • CFM46350 · Deemed loan relationships: repos: tax rules: debtor repos
  • CFM46360 · Deemed loan relationships: repos: tax rules: debtor quasi-repo
  • CFM46370 · Deemed loan relationships: repos: tax rules: debtor quasi-repos: examples
  • CFM46380 · Deemed loan relationships: repos: tax rules: debtor quasi-repo: first tax consequence
  • CFM46390 · Deemed loan relationships: repos: tax rules: debtor quasi-repo: first tax consequence: exception
  • CFM46400 · Deemed loan relationships: repos: tax rules: debtor quasi-repo: first tax consequence: ‘relevant arrangements’
  • CFM46410 · Deemed loan relationships: repos: tax rules: debtor repos and debtor quasi-repos: second tax consequence
  • CFM46420 · Deemed loan relationships: repos: tax rules: debtor and debtor quasi-repos: further examples
  • CFM46430 · Deemed loan relationships: repos: tax rules: debtor and debtor quasi-repos: further examples: no income
  • CFM46440 · Deemed loan relationships: repos: tax rules: debtor and debtor quasi-repos: further examples: gross-paying
  • CFM46450 · Deemed loan relationships: repos: tax rules: debtor and debtor quasi-repos: further examples: net-paying
  • CFM46460 · Deemed loan relationships: repos: tax rules: debtor and debtor quasi-repos: further examples: debtor quasi-repo
  • CFM46470 · Deemed loan relationships: repos: tax rules: creditor and debtor repos: capital gains consequences
  • CFM46480 · Deemed loan relationships: repos: tax rules: regulation-making powers
  • CFM46490 · Deemed loan relationships: repos: tax rules: regulations: substitution or redemption of securities
  • CFM46500 · Deemed loan relationships: repos: tax rules: back to back repos
  • CFM46510 · Deemed loan relationships: repos: tax rules: interaction with other tax rules
  • CFM46520 · Deemed loan relationships: repos: tax rules: other types of repo
  • CFM46530 · Deemed loan relationships: repos: tax rules: deduction of tax
  1. Deemed loan relationships: manufactured interest and repos: contents
  2. Deemed loan relationships: repos: general collateral repos: examples

CFM46120 | Deemed loan relationships: repos: general collateral repos: examples

From HM Revenue & Customs · Corporate Finance Manual

Example of a general collateral repo

-Shares/gilts/bonds-
- Original Owner-Interim Holder
Day 1--
-£100 million cash-
-Shares/gilts/bonds-
- Original Owner-Interim Holder
Day 90--
-£101 million cash-

You can see that the repurchase price is £1m, or 1%, greater than the sales price. 1% for 90 days equates to approximately 4% p.a. on a simple basis. The transaction is in substance a lending one.

Extended example of a standard repo

A (repo seller) enters into repo with B (repo buyer). 1st leg settlement is on 15/4 and the repo is for 28 days (term is on 13/5). The repo rate is 4% and collateral is £60m nominal 8.5% bond with annual coupons payable on 31/12. Clean price of the bond is 107.5 on 15/4. A haircut of 2% is required. The sale and repurchase prices are calculated below.

15 April

  • £60 million 8.5% bonds -B

  • Cash £65 million - A

Dirty Price of Collateral = (107.5 + (8.5 x105/360))/100 x 60 million = £65.99 million

Haircut @ 2%: cash advance = £65.99 million /1.02 = £64.69 million rounded to £65 million by B for purchase of securities.

13 May

  • £60 million bonds

  • Cash £65. 2 million

Repurchase Price = £65 million x 4% x 28/360 + £65 million = £65.20 million

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