Peter Halford (PwC Legal) reviews the decision in Trigg v HMRC, where the FTT held that euro redenomination clauses did not deprive bonds of QCB status.
In Trigg v HMRC [2014] UKFTT 967 (TC) the First-tier Tribunal held that certain clauses in sterling bonds which provided for their conversion into euros in the event of the UK adopting the euro did not prevent the bonds from being qualifying corporate bonds (QCBs). Capital gains on disposal of the bonds were therefore exempt from CGT under TCGA 1992 s 115.
The taxpayer was an individual investor in a limited liability partnership Tonnant LLP investing in bonds and established to exploit perceived market undervaluations. The case was a rule 18 ‘lead case’ for the other investors in the LLP ...
