[CFM72680] Other tax rules on corporate finance: securitisation: periods beginning on or after 1 January 2007: the regulations: modifications to other tax rules: other points
Other tax rules
See INTM566010 for guidance on thin capitalisation issues in securitisation structures, and INTM430000 for more on transfer pricing rules generally. A securitisation company within the regulations calculates its profit in accordance with Regulation 14 and not on the basis of its profits. It cannot self-assess an adjustment to those profits under TIOPA10/Part 4, nor can such an adjustment be sought by HMRC.