Corporation Tax Act 2010 section 805

"Stock lending arrangement"

Section 805 defines what constitutes a "stock lending arrangement" for the purposes of the corporation tax rules on manufactured payments and repos.

• A stock lending arrangement is one where a person (the lender) transfers securities to another person (the borrower), and the borrower is required to transfer equivalent securities back to the lender at a later date.
• The definition covers arrangements where the lender retains the economic interest in the securities, even though legal ownership temporarily passes to the borrower.
• The section is an interpretative provision that supports other rules dealing with the tax treatment of manufactured payments, stock lending and repurchase arrangements.
• The definition was amended by Finance Act 2013 to align with updated provisions on disguised interest and lending arrangements.

---