CFM72600 - Other tax rules on corporate finance: securitisation: periods beginning on or after 1 January 2007: the regulations: the corporation tax charge: the 바카라 사이트˜specified amount바카라 사이트™
The 바카라 사이트˜specified amount바카라 사이트™ under Regulation 14(3)
There is one further amount that may be added to the corporation tax charge. CFM72660 explains that the loan relationship and derivative contracts rules are amended so that any profit or loss on the disposal of a loan relationship or derivative contract intra-group is taxed on the originator company where the disposal is to a securitisation company. This is achieved by disapplying the rules in CTA09/PT5/CH4 and CTA09/PT7/CH5.
Where such a transfer took place before the commencement of the securitisation regime, CTA09/PT5/CH4 or CTA09/PT7/CH5 may have already applied on a disposal to a securitisation company. An 바카라 사이트˜exit charge바카라 사이트™ under CTA09/S344 - S346 or CTA09/S630 - 632 may therefore arise on the securitisation company in respect of one of these disposals. This rule therefore ensures that any charge under CTA09/S344 or CTA09/S630 is added to the taxable profits calculated under Regulation 14.