[2008] EWCA Civ 1164.

Court of Appeal (Civil Division).

Rix, Richards and Lawrence Collins L JJ.

Judgment delivered 23 October 2008.

Capital gains tax – Qualifying corporate bonds (QCBs) – Shares exchanged for loan notes with foreign currency redemption option – Foreign currency option not exercised and lapsed – Loan note later redeemed – Whether loan notes became QCBs once foreign currency option lapsed – Taxation of Chargeable Gains Act 1992, s. 116, 117, 132, 135.

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