.png)
.png)
Conversion clause
KEY POINTS
- Partnership bought undervalued bonds sold them
and claimed exemption from capital gains tax under TCGA 1992 s 115. - Effect of foreign currency conversion on qualifying corporate bonds.
- Court of Appeal said the bonds did not contain provisions for their conversion as in TCGA 1992 s 117(1)(b).
- Case concerned only euro-conversion clauses in bonds.
Nicholas Trigg was a member of Tonnant LLP a partnership that bought some undervalued bonds and later sold them at a profit. He argued that these were qualifying corporate bonds (QCBs) and therefore exempt from capital gains tax (TCGA 1992 s 115). HMRC said the bonds were not QCBs (non-QCBs) so capital gains tax was due. The bonds concerned each had one of two schedules that were intended to activate if the...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
