Trigg, Vaines, Goldsmith, Khan Properties and more... Andrew Goldstone and Stuart Adams (Mishcon de Reya) review recent key developments in the private client world.
Trigg: whether bonds were QCBs
In Trigg v HMRC [2018] EWCA Civ 17 Mr Trigg (T) purchased and subsequently sold six corporate bonds denominated and redeemable in pounds sterling. Accordingly it was assumed by T that the bonds were qualifying corporate bonds (QCBs) and exempt from CGT under TCGA 1992 s 115. As such T did not report a chargeable gain.
Put briefly a QCB is a security which is expressed in sterling and in respect of which no provision is made for redemption in any currency other than sterling. HMRC argued that the gain was chargeable because of the inclusion of certain (reasonably vanilla) clauses within the bonds which allowed for the...
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Trigg, Vaines, Goldsmith, Khan Properties and more... Andrew Goldstone and Stuart Adams (Mishcon de Reya) review recent key developments in the private client world.
Trigg: whether bonds were QCBs
In Trigg v HMRC [2018] EWCA Civ 17 Mr Trigg (T) purchased and subsequently sold six corporate bonds denominated and redeemable in pounds sterling. Accordingly it was assumed by T that the bonds were qualifying corporate bonds (QCBs) and exempt from CGT under TCGA 1992 s 115. As such T did not report a chargeable gain.
Put briefly a QCB is a security which is expressed in sterling and in respect of which no provision is made for redemption in any currency other than sterling. HMRC argued that the gain was chargeable because of the inclusion of certain (reasonably vanilla) clauses within the bonds which allowed for the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
