Currency fluctuation losses arising from a loan to a subsidiary overseas company were not allowable against capital gains tax. The words ‘the debt on a security’ in section 117(1)can refer to an obligation to pay or repay embodied in the Loan Note, which is evidence of the right to receive payment.
Times 24-Mar-1997, [1997] STC 499
Capital Gains Tax Act 1979 117 134
England and Wales
Cited by:
Appeal from – Taylor Clark International Limited v Lewis (HM Inspector of Taxes) CA 18-Nov-1998
Security exchange losses on interest-bearing loan were not to be set off against capital gains as being a debt on a security even though secured. Being simply secured itself was insufficient to make a debt a debt on a security. . .
Cited – Harding 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.
Updated: 30 July 2021; Ref: scu.89737
