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 transaction of non-QCBs and QCBs into QCBs or two separate transactions – whether the conversion and redemption should be treated as a single composite transaction of the disposal/redemption of non-QCBs – the Ramsay principle
Citations:
[2016] UKUT 81 (TCC), [2016] STI 432, [2016] STC 1433, [2016] BTC 503
Links:
Jurisdiction:
England and Wales
Citing:
At FTTTx – Hancock and Hancock v Commissioners for Inland Revenue and Customs FTTTx 21-Jul-2014
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 . .
Cited by:
At UTTC – 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 UTTC – 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.562426