Are bonds which may be redenominated in euros QCBs?
In Nicholas Trigg v HMRC [2014] UKFTT 967 (20 October 2014) the FTT found that bonds which could be redominated in euros should the UK adopt the euro were QCBs.
The terms of the bonds identified risk factors. One risk was that the UK might adopt the euro before the redemption date so that the bonds would be redenominated in euros. HMRC therefore argued that the bonds were not QCBs as their terms allowed for their ‘conversion or redemption in a currency other than sterling’ (TCGA 1992 s 117). This in turn meant that CGT was due on their disposal.
The FTT accepted HMRC’s argument that Parliament had meant British pounds sterling when it referred to sterling in s 117. However a purposive interpretation of the provision suggested that the QCB exemption was...
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Are bonds which may be redenominated in euros QCBs?
In Nicholas Trigg v HMRC [2014] UKFTT 967 (20 October 2014) the FTT found that bonds which could be redominated in euros should the UK adopt the euro were QCBs.
The terms of the bonds identified risk factors. One risk was that the UK might adopt the euro before the redemption date so that the bonds would be redenominated in euros. HMRC therefore argued that the bonds were not QCBs as their terms allowed for their ‘conversion or redemption in a currency other than sterling’ (TCGA 1992 s 117). This in turn meant that CGT was due on their disposal.
The FTT accepted HMRC’s argument that Parliament had meant British pounds sterling when it referred to sterling in s 117. However a purposive interpretation of the provision suggested that the QCB exemption was...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
