CFM72310 - Other tax rules on corporate finance: securitisation: periods beginning on or after 1 January 2007: 鈥榓lternative finance鈥� arrangements

Alternative finance investment bonds

ITA 2007/PT10A provide tax rules on a form of Shari鈥檃 compliant bond known as 鈥榮ukuk鈥�. The legislation refers to this as an 鈥榓lternative finance investment bond鈥�. CFM44000.

There is no debt obligation to investors in such instruments, but the tax rules in ITA 2007/PT10A treat them as securities for tax purposes, where they are economically equivalent to conventional bonds. A company issuing sukuk can therefore come within the securitisation regulations, subject to meeting the other conditions in CTA10/S623 and in the Taxation of Securitisation Companies Regulations 2006.