Harding v HM Revenue and Customs: ChD 30 Jan 2008

In section 117 the word ‘security’ identified an asset in the nature of an investment. It was used as meaning something distinct from the debt on it referred to in section 117(1)(a), but it was not simply a reference to the document which evidenced the debt.

Briggs J
[2008] EWHC 99 (Ch), [2008] STC 1865
Taxation of Chargeable Gains Act 1992 117
England and Wales
Appeal fromHarding v Revenue and Customs SCIT 15-Mar-2007
SCIT Capital Gains Tax – qualifying corporate bonds (QCBs) – shares exchanged for loan notes with foreign currency redemption option – section 135 TCGA applying to exchange – loan notes not QCBs on exchange – . .

Cited by:
Appeal fromHarding v Revenue and Customs CA 23-Oct-2008
Lapsed Currency conversion option lost status
The taxpayer appealed his assessment to Capital Gains Tax on his redemption of loan notes arising following the sale of his computer company. He said that they were qualifying corporate bonds. The question was whether a security in which a currency . .

Lists of cited by and citing cases may be incomplete.

Capital Gains Tax

Updated: 23 December 2021; Ref: scu.264024