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Contents

Official guidance
Corporate Finance Manual

CFM72000 · Other tax rules on corporate finance: securitisation

  • CFM72010 · Background
  • CFM72020 · Background: basic terminology
  • CFM72030 · Background: true sale/asset-backed securitisation
  • CFM72040 · Background: true sale/asset-backed securitisation: example
  • CFM72050 · Background: master trust securitisation
  • CFM72060 · Background: master trust securitisation: example
  • CFM72070 · Background: whole business and other types of securitisation
  • CFM72080 · Background: synthetic securitisation: example
  • CFM72090 · Background: SPVs and other common features
  • CFM72100 · Periods beginning before 1 January 2005
  • CFM72110 · Periods beginning before 1 January 2005: general points
  • CFM72120 · Periods beginning before 1 January 2005: bad and doubtful debts
  • CFM72130 · Periods beginning before 1 January 2005: offshore SPVs
  • CFM72140 · Periods beginning before 1 January 2005: example
  • CFM72200 · Periods beginning on or after 1 January 2005: overview of the new rules
  • CFM72210 · Periods beginning on or after 1 January 2005: the interim regime
  • CFM72220 · Periods beginning on or after 1 January 2005: the interim regime: definitions
  • CFM72230 · Periods beginning on or after 1 January 2005: the interim regime: the note-issuing company
  • CFM72240 · Periods beginning on or after 1 January 2005: the interim regime: other types of securitisation company
  • CFM72250 · Periods beginning on or after 1 January 2005: the interim regime: application of former UK GAAP
  • CFM72260 · Periods beginning on or after 1 January 2005: the interim regime: continuation after 2008
  • CFM72270 · Periods beginning on or after 1 January 2005: the interim regime: continuation after 2008: transitional rules
  • CFM72300 · Periods beginning on or after 1 January 2007: the permanent regime
  • CFM72310 · Periods beginning on or after 1 January 2007: ‘alternative finance’ arrangements
  • CFM72320 · Periods beginning on or after 1 January 2007: the regulations
  • CFM72330 · Periods beginning on or after 1 January 2007: the regulations: commencement
  • CFM72340 · Periods beginning on or after 1 January 2007: the regulations: interpretation
  • CFM72350 · Periods beginning on or after 1 January 2007: the regulations: interpretation: ‘financial assets’
  • CFM72360 · Periods beginning on or after 1 January 2007: the regulations: scope
  • CFM72370 · Periods beginning on or after 1 January 2007: the regulations: meaning of a ‘securitisation company’
  • CFM72380 · Periods beginning on or after 1 January 2007: the regulations: the note-issuing company
  • CFM72390 · Periods beginning on or after 1 January 2007: the regulations: the note-issuing company: ‘independent persons’
  • CFM72400 · Periods beginning on or after 1 January 2007: the regulations: the note-issuing company: incidental activities
  • CFM72410 · Periods beginning on or after 1 January 2007: the regulations: the asset-holding company
  • CFM72420 · Periods beginning on or after 1 January 2007: the regulations: the asset-holding company: partnerships
  • CFM72430 · Periods beginning on or after 1 January 2007: the regulations: the asset-holding company: subordinated debt
  • CFM72440 · Periods beginning on or after 1 January 2007: the regulations: intermediate borrowing companies
  • CFM72450 · Periods beginning on or after 1 January 2007: the regulations: warehouse companies
  • CFM72460 · Periods beginning on or after 1 January 2007: the regulations: warehouse companies: abortive warehouse arrangements
  • CFM72470 · Periods beginning on or after 1 January 2007: the regulations: commercial paper funded companies
  • CFM72480 · Periods beginning on or after 1 January 2007: the regulations: ‘retained profit’
  • CFM72490 · Periods beginning on or after 1 January 2007: the regulations: ‘retained profit’: dividends received
  • CFM72500 · Periods beginning on or after 1 January 2007: the regulations: conditions to be met by securitisation companies
  • CFM72510 · Periods beginning on or after 1 January 2007: the regulations: the payments condition: introduction
  • CFM72520 · Periods beginning on or after 1 January 2007: the regulations: the payments condition: the formula
  • CFM72530 · Periods beginning on or after 1 January 2007: the regulations: the payments condition: examples of ‘RA’
  • CFM72540 · Periods beginning on or after 1 January 2007: the payments condition: meaning of payment
  • CFM72550 · Periods beginning on or after 1 January 2007: the payments condition: failure to make a payment
  • CFM72560 · Periods beginning on or after 1 January 2007: the payments condition: other points
  • CFM72570 · Periods beginning on or after 1 January 2007: the unallowable purposes rule
  • CFM72580 · Periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: the formula: ‘RP’ and ‘DS’
  • CFM72590 · Periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: the formula: ‘D’
  • CFM72600 · Periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: the ‘specified amount’
  • CFM72610 · Periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: applies instead of the normal CT rules
  • CFM72620 · Periods beginning on or after 1 January 2007: modifications to commencement and cessation rules
  • CFM72630 · Periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules
  • CFM72640 · Periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: group relief
  • CFM72650 · Periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: capital assets
  • CFM72660 · Periods beginning on or after 1 January 2007: the regulations: modifications to certain tax rules: loan relationships
  • CFM72670 · Periods beginning on or after 1 January 2007: the regulations: modifications to certain tax rules: derivative contracts
  • CFM72675 · Periods beginning on or after 1 January 2018: the regulations: modifications to certain tax rules: recovery of unpaid corporation tax
  • CFM72680 · Periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: other points
  • CFM72690 · Periods beginning on or after 1 January 2007: credit card securitisations
  • CFM72700 · Periods beginning on or after 1 January 2007: modifications to other tax rules: taxation of the investor
  • CFM72710 · Periods beginning on or after 1 January 2007: other types of securitisation company
  1. Other tax rules on corporate finance: securitisation: contents
  2. Other tax rules on corporate finance: securitisation: background: true sale/asset-backed securitisation: example

CFM72040 | Other tax rules on corporate finance: securitisation: background: true sale/asset-backed securitisation: example

From HM Revenue & Customs · Corporate Finance Manual

True sale/asset-backed securitisation

Diagram of a true sale/asset-backed securitisation.

Text Alternative

A charitable trust is formed that owns the equity in an issuer SPV.

The originator company sells suitable assets to the issuer SPV.

The issuer SPV raises the finance to purchase the assets from the originator by issuing bonds to third party investors which represent both interest and principal.

Any ongoing surpluses made by the issuer SPV are passed back to the originator.

Any residual profit left in the issuer SPV is passed back to the charitable trust.

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