The court considered the taxation of ‘repo’ transactions. The revenue had charged to tax, an element of interest paid on a block og gilts purchased by the taxpayer company under a resale agreement at a price which allowed for the interest payments to be made.
Held: The revenue’s appeal succeeded.
Norris J
[2008] EWHC 2429 (Ch), [2009] STC 77, [2008] STI 2319, [2008] BTC 755
Bailii
Income and Corporation Taxes Act 1988 730A, Finance Act 1996 84(1)
England and Wales
Citing:
Appeal from – DCC Holdings (UK) Ltd v Revenue and Customs SCIT 8-May-2007
Gilt repo – purchase and resale of gilts – interest paid to interim holder not required to be paid to original holder but recognised in repurchase price – application of paragraph 15 Schedule 9 FA 96 – related transaction – effect of section 737A to . .
Cited by:
Appeal from – Revenue and Customs v DCC Holdings (UK) Ltd CA 10-Nov-2009
The company had entered into an agreement to purchase gilts, and at the same time to resell them at a future date for a fixed sum. In effect they provided a loan against the gilts. It sought to offset the profit against its trading losses.
In Chancery – Revenue and Customs v DCC Holdings (UK) Ltd SC 15-Dec-2010
The taxpayer had entered into a ‘repo’ loan to its bank, agreeing to purchase a block of gilt edged securities, and to resell them at a later date at a fixed figure. The profit and figures included an allowance for the interest payments to be made. . .
Lists of cited by and citing cases may be incomplete.
Updated: 16 October 2021; Ref: scu.277023 br>