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The Upper Tribunal found a new angle on non-qualifying corporate bonds and finds the result reassuring for advisers.
KEY POINTS
- A partnership bought undervalued bonds sold them at a profit and claimed exemption from capital gains tax under TCGA 1992 s 115.
- The First-tier Tribunal ruled that under the bond provisions the claimed relief was due.
- This decision was overruled by the Upper Tribunal which took a purposive construction.
- The Upper Tribunal held that the word sterling meant pounds sterling the lawful UK currency.
- The longevity of the provisions was highlighted and the outcome was ‘neither illogical nor absurd’.
Mr Trigg was a member of a partnership that bought some undervalued bonds and later sold them at a profit. He argued that these were qualifying corporate bonds (QCBs) and were therefore exempt from capital gains tax under TCGA 1992 s...
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