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The conditions that must be met for a company to be a securitisation company for the purpose of the permanent regime are set out at D7.218. Details of the taxation of securitisation companies within the permanent regime are set out at D7.215 and an overview of securitisation generally can be found at D7.205.

In order for the special tax regime to apply a securitisation company must:

1. Ìý

   •ÌýÌýÌýÌý have provision for a retained profit. The requirement to have a retained profit means that there must be provision for a retained profit under the documentation for the related capital market arrangement (CMA) (see D7.218 for a discussion of the definition of CMA)

2. Ìý

   •ÌýÌýÌýÌý satisfy the payments condition¹ and

3. Ìý

   •ÌýÌýÌýÌý meet the unallowable purposes test²

If a company fails to meet these conditions the special corporation tax charge³, the removal of withholding obligation under ITA 2007, s 901⁴ and the modifications to the corporation tax rules⁵ will not apply to it. Such a company