Income Tax Act 2007 section 610

Repurchase price in deemed manufactured payment case

Section 610 deals with how the rules on repurchase agreements (repos) interact with the rules on stock lending arrangements, specifically where a deemed manufactured payment arises.

• This section addresses the overlap between the repo rules (Chapter 4) and the stock lending rules (Chapter 5) within the same Part of the Act.
• It applies where a repurchase arrangement gives rise to a deemed manufactured payment — that is, where the repurchase price is treated as including a payment representing income on the securities.
• The section ensures that the repurchase price used in the repo calculations is adjusted to reflect the deemed manufactured payment, preventing double counting or omission of the income element.
• The provision originates from section 730A of the Income and Corporation Taxes Act 1988 (ICTA) and was amended by Finance Act 2013.