Sukuk al ijara—relief from tax on chargeable gains under FA 2009, Sch 61

Produced in partnership with Sarah Squires of Old Square Tax Chambers
Practice notes

Sukuk al ijara—relief from tax on chargeable gains under FA 2009, Sch 61

Produced in partnership with Sarah Squires of Old Square Tax Chambers

Practice notes
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Sukuk (singular form: ‘sakk’) is a type of Shari’a financing arrangement also referred to as Islamic bonds or certificates. For more information, see Practice Note: Sukuk—investment bond arrangements and their UK direct tax treatment—What are sukuk? Sukuk may benefit from the UK tax treatment provided to alternative finance investment bond (AFIB) arrangements if all the relevant conditions are met. For more information on those rules, see Practice Note: Sukuk—investment bond arrangements and their UK direct tax treatment.

Sukuk al ijara is a particular form of sukuk. Under a sukuk al ijara, the asset held by the bond-issuer (the term the legislation uses to refer to the sukuk issuer) on trust for the investors in the sukuk (the certificate holders) is often land. The issuer acquires an interest in land by way of a sale and leaseback—it is this sale and leaseback arrangement that is the ijara. For more information, see Practice Notes: Sukuk al ijara—tax reliefs for sale and leaseback arrangements—What is sukuk al ijara?, The

Sarah Squires
Sarah Squires

Sarah is a barrister at Old Square Tax Chambers, having been called to the bar in 2017. She has significant corporate tax experience, having practised a as a solicitor in leading City firms prior to re-qualifying as a barrister. She started her professional career in the tax department of Linklaters and then, following a move to Clifford Chance LLP in 2000, became a partner in their tax group in 2002. Sarah is a member of the Law Society Tax Law Committee. In addition, she also acts as a consultant to various trade and other representation bodies on tax policy matters. Sarah's practice is focused on general business and corporate tax matters, including in relation to real estate, finance and capital markets transactions.

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Jurisdiction(s):
United Kingdom
Key definition:
Bonds definition
What does Bonds mean?

A certificate of debt issued, eg by a government or a company.

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