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The Finance Act 2007 makes new provision relating to arrangements involving the sale and repurchase of securities (more commonly known as “repos”).
The tax liability arising from a repo transaction is generally a liability to corporation tax; but, in appropriate cases, a liability to income tax or to capital gains tax may arise. These Regulations accordingly exercise powers conferred by the Income Tax Act 2007 and the Taxation of Chargeable Gains Act 1992 to modify provisions in those Acts so that non-standard repo cases and cases involving redemption arrangements are dealt with in the same way for income tax and capital gains tax as for corporation tax.
A full regulatory impact assessment has not been produced for this instrument as no impact on the private or voluntary sectors is foreseen.
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