Dr John F Avery Jones.

Decision released 29 July 2003.

Capital gains tax – qualifying corporate bond – loan note convertible into relevant discounted security itself convertible into ordinary shares – whether loan note represented normal commercial loan – Taxation of Chargeable Gains Act 1992, s. 117Income and Corporation Taxes Act 1988, Sch. 18, para. 1(5).


Certain loan notes which were convertible into relevant discounted securities, which were themselves convertible into ordinary shares, did not represent normal commercial loans so that the taxpayer was not entitled to exemption from capital gains tax on their disposal.


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