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 737C and 730A TA 88 – effect of section 97 FA 96 – approach to section84 FA 96 – section 86 FA 96 determining which authorised accounting method to use.
 UKSPC SPC00611,  STI 1649,  STC (SCD) 592
Finance Act 1996 84(1), Income and Corporation Taxes Act 1988 730A 737A
England and Wales
Appeal from – DCC Holdings (UK) Ltd v HM Revenue and Customs ChD 17-Oct-2008
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 . .
At Special Commissioners – 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.
At Special Commissioners – 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: 23 November 2021; Ref: scu.253403