The Securitisation Companies and Qualifying Transformer Vehicles (Exemption from Stamp Duties) Regulations, SI 2022/464, provide an exemption from stamp duty and stamp duty reserve tax (SDRT) for the transfer of certain types of loan notes issued as part of securitisation and insurance-linked securities arrangements.
The standard loan notes issued as part of securitisation and insurance-linked securities (ILS) arrangements, known as ‘capital market investments’, commonly have characteristics which make it unlikely or uncertain that the loan capital exemption from stamp duty and SDRT will apply.
By providing certainty that a charge to stamp duty or SDRT will not arise on the standard loan notes, the regulations will reduce the cost and complexity of securitisation and ILS arrangements and encourage their location in the UK. The regulations come into force on 17 May 2022.
The Securitisation Companies and Qualifying Transformer Vehicles (Exemption from Stamp Duties) Regulations, SI 2022/464, provide an exemption from stamp duty and stamp duty reserve tax (SDRT) for the transfer of certain types of loan notes issued as part of securitisation and insurance-linked securities arrangements.
The standard loan notes issued as part of securitisation and insurance-linked securities (ILS) arrangements, known as ‘capital market investments’, commonly have characteristics which make it unlikely or uncertain that the loan capital exemption from stamp duty and SDRT will apply.
By providing certainty that a charge to stamp duty or SDRT will not arise on the standard loan notes, the regulations will reduce the cost and complexity of securitisation and ILS arrangements and encourage their location in the UK. The regulations come into force on 17 May 2022.
