Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Originator definition

What does Originator mean? In pharmaceutical regulatory practice, originator describes the first authorised branded medicine used as the comparator for later generics and biosimilars. The term is descriptive (not a defined statutory term) and is used interchangeably with reference medicinal product. Under Directive 2001/83/EC, the reference medicinal product is one holding a marketing authorisation supported by a complete, stand‑alone dossier under Article 8(3) (not an abridged dossier under Articles 10a, 10b or 10c). Generic applications under Article 10 rely on demonstrating bioequivalence to the originator; biosimilar applications demonstrate biosimilarity to a reference biological. The originator matters because it: - identifies the lawful comparator for...

UK tax opinion for asset-backed securitisations: corporation tax regime, withholding tax, VAT, stamp duty/SDRT, secondary liabilities and Pillar Two—scope and typical confirmations

Published by a LexisNexis Tax expert

Practice notes

This Practice Note

This Practice Note explains the typical scope of a UK tax opinion prepared by tax lawyers for a UK tax resident securitisation company participating in an asset-backed securitisation (ABS, sometimes called a true sale securitisation). In essence, an ABS is a structure in which a company (the Originator) converts value by selling its assets to an orphan Special purpose vehicle (SPV) to generate cash. The SPV finances that purchase by issuing listed notes to investors, and the assets supporting the securitisation are referred to as securitised assets...

A distinct corporation tax regime applies to entities that meet the criteria below:

Qualify as securitisation companies; and
Meet two further conditions:
- The unallowable purposes test; and
- The payments condition

This regime is contained in the Taxation of Securitisation Companies Regulations 2006 (Securitisation Regs), SI 2006/3296, commonly known as the permanent securitisation regime. For further detail on this framework, see Practice Note: Asset-backed securitisations—the UK tax treatment. In practice, ABS arrangements can depart from the simple model above and may include an asset-holding company alongside a separate note-issuing vehicle...

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Web page updated on 22/05/2026

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