FTTTx Capital gains tax – redemption of qualifying corporate bonds (QCBs) – scheme to avoid the application of s 116, TCGA to a conversion of non-QCBs into QCBs – s 116(1)(b) – whether a single conversion of non-QCBs and QCBs into QCBs or two separate conversions – whether the conversion and redemption should be treated as a single composite transaction of the disposal/redemption of non-QCBs – the Ramsay principle
Judges:
Robert Berner TJ
Citations:
[2014] UKFTT 695 (TC), [2014] STI 2978, [2014] SFTD 1163
Links:
Jurisdiction:
England and Wales
Cited by:
At FTTTx – Revenue and Customs v Hancock and Another UTTC 18-Feb-2016
UTTC Capital gains tax – redemption of qualifying corporate bonds (QCBs) – scheme to avoid the application of s 116 TCGA to a conversion of non-QCBs into QCBs – s 116(1)(b) and s 132 – whether a single . .
At FTTTx – Hancock and Another v Revenue and Customs CA 25-May-2017
interaction of the rules which relate to corporate reorganisations and those which relate to qualifying corporate bonds . .
At FTTTx – Hancock and Another v Revenue and Customs SC 22-May-2019
The taxpayers sold their shares in return for loan notes in the form of mixed qualifying (QCB) and non qualifying corporate bonds (Non-QCB) within section 115 of the 1992 Act. Gains on the disposal of QCB would be exempt from CGT. These were then . .
Lists of cited by and citing cases may be incomplete.
Capital Gains Tax
Updated: 07 February 2022; Ref: scu.535144