[2006] 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).

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