Consolidated accounting

Derecognition

Distribution, non-deductible

Extracting profit from transaction

Deferred consideration

Dividends

Fees

Parallel loans

Receivables trust

Subordinated loans

Swaps

Further VAT issues

Generally

Interest, tax deductions for

Lease receivables wiithout transfer of title to equipment

Bad-debt relief

Capital account

Generally

Interest deduction, calcualtion

Issuer

Loan relationships

Originator

Originator – capital allowances

Originator – operating leases

Originator – relevance of accounting treatment

Rating of notes

VAT

Reasons for

Sale receivables with transfer of title to equipment

Corporation tax: issuer

Corporation tax: originator

Costs incurred by issuer

Extracting profit from transaction

Interposed an immediate company

Matching the requirements of originator and issuer

Non-resident issuer

Rent factoring

Stamp duty

VAT

Security of leased assets, raising loan finance

VAT and stamp duty

Withholding tax