Cadbury Schweppes plc & Anor v Williams (HMIT).  BTC 440
 EWCA Civ 657.
Court of Appeal (Civil Division).
[Croner-i has been notified that an appeal against this decision is pending.]
Morritt C, Tuckey LJ and Sir Peter Gibson.
Judgment delivered 24 May 2006.
Corporation tax – Transfer of securities – Loan notes – Promissory notes expressed to carry interest at fixed rate from issue to redemption – Irregular interest payment profile – Interest to be paid in different amounts for different periods – Notes subject to variable interest rate taxation regime – Notes not carrying interest at same rate ‘throughout’ period – Income and Corporation Taxes Act 1988, s. 717(2)(a).