Part 3 Domestic Top-up Tax

Part 3 Domestic Top-up Tax

Securitisation entities

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(1)     In section 267 (DTT excluded entities)—

(a)     after subsection (3) insert—

“(3A)     A securitisation company that is not a member of a group for the purposes of domestic top-up tax is a DTT excluded entity (and see section 267A).â€

(b)     in subsection (4)—

(i)     the words from ““qualifying†to the end become the first definition, and

(ii)     after that definition insert—

““securitisation company†has the meaning it has in the Taxation of Securitisation Companies Regulations 2006 (see regulation 4).â€

(2)     After section 267 insert—

“267A Securitisation companies in a group treated as not consolidated

(1)     Subsection (2) applies to a securitisation company that is a member of a group.

(2)     The company is only to be regarded as a member of the group for the purposes of applying Condition C in section 266 in relation to other members of the group (revenue threshold for group).

(3)     Otherwise, the company is to be treated as not being a member of any group for the purposes of domestic top-up tax.â€

(3)     After section 272 insert—

“272A Treatment of covered bond vehicles

(1)     This section applies where—

(a)

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