Corporation tax – disposal of qualifying corporate bonds – disposal of debts – section 116(10) Taxation of Chargeable Gains Act 1992 – held-over capital gain brought into charge – joint election under section 171A TCGA – whether disposal by repayment of the debt underlying the bonds is a disposal ‘to’ a person outside the corporate group – whether the bonds exist after the repayment of the debt and are disposed of ‘to’ the debtor – reliance on extra-statutory material for construction of relevant provisions
Citations:
[2014] UKUT 98 (TCC), [2014] STC 1440, [2014] BTC 509, [2014] STI 880
Links:
Jurisdiction:
England and Wales
Corporation Tax
Updated: 06 February 2022; Ref: scu.525875
