Matthew Mortimer and Tamar Ruiz (Mayer Brown) provide an overview of the tax treatment of derivatives, repo and stock loan transactions for UK companies.
Tax practitioners will sometimes encounter derivatives and even repos and stock loans in relation to the transactions they advise upon. Such derivatives repos or stock loans may be central to the transactions in question or play a more ancillary role such as the conversion of floating rate interest payments under a borrowing into fixed rate ones by means of an interest rate swap (see also below). Two key questions usually arise in relation to this type of transaction: how and where are they taxed and what tax-related provision needs to be made for them in relevant contracts?
Thankfully some of the heavy lifting in relation to the second question will be achieved under market standard documentation in the relevant areas such as...
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Matthew Mortimer and Tamar Ruiz (Mayer Brown) provide an overview of the tax treatment of derivatives, repo and stock loan transactions for UK companies.
Tax practitioners will sometimes encounter derivatives and even repos and stock loans in relation to the transactions they advise upon. Such derivatives repos or stock loans may be central to the transactions in question or play a more ancillary role such as the conversion of floating rate interest payments under a borrowing into fixed rate ones by means of an interest rate swap (see also below). Two key questions usually arise in relation to this type of transaction: how and where are they taxed and what tax-related provision needs to be made for them in relevant contracts?
Thankfully some of the heavy lifting in relation to the second question will be achieved under market standard documentation in the relevant areas such as...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
