CFM72230 - Other tax rules on corporate finance: securitisation: periods beginning on or after 1 January 2005: the interim regime: the note-issuing company

Note-issuing company

»Ê¹ÚÌåÓýapp note issuing company is the company that issues notes to the investors. It is the key company in the securitisation tax rules. »Ê¹ÚÌåÓýapp other four types of securitisation company (CFM72240) are defined by their relationship to it.

»Ê¹ÚÌåÓýapp note-issuing company must satisfy the following conditions:

  • it must be party as debtor to a capital market investment (CMI);
  • the securities in that CMI must be issued wholly or mainly to independent persons;
  • the CMI must be part of a capital market arrangement (CMA), and amount to at least £50m;
  • any business the note-issuing company carries on must be that of acquiring, holding and managing the assets or acting as guarantor for such assets.

»Ê¹ÚÌåÓýapp definition is very similar to that of a note-issuing company in the permanent regime, and the guidance at CFM72380 onwards should be referred to in point of interpretation. »Ê¹ÚÌåÓýapp key differences are that the assets in question are not restricted to ‘financial assetsâ€� (CFM72350), and their total value must be at least £50m rather than £10m. »Ê¹ÚÌåÓýapp same principles apply to the £50m threshold as to the £10m threshold in the permanent regime.