Klincke v Revenue and Customs: FTTTx 1 Jul 2009

FTTTx CGT – Exemption and relief – Disposal of qualifying corporate bond: (‘QCB’) – Taxpayer acquiring loan notes in exchange for shares – Loan notes not QCBs at time of acquisition – Loan notes containing currency conversion right exercisable by issuer – Right cancelled – Whether notes becoming QCBs following cancellation of issuer’s currency conversion right – TCGA 1992 s117(2)
CGT – Conversion of securities – Crystallisation of capital gain on securities while non-QCBs – Whether transaction required to cancel issuer’s currency conversion right amounted to conversion – Yes – TCGA 1992 s132


[2009] UKFTT 156 (TC)




England and Wales

Capital Gains Tax

Updated: 03 August 2022; Ref: scu.373702