[2015] EWCA Civ 1036

Court of Appeal (Civil Division)

Lord Justice Moore-Bick, Lord Justice Lewison, And Sir Timothy Lloyd

Judgment delivered 20 October 2015

Corporation tax – Disposal of qualifying corporate bonds – Taxation of Chargeable Gains Act 1992 (‘TCGA 1992’), s. 116(10) – Held-over chargeable gains brought into charge – Joint election under TCGA 1992, s. 171A – Whether disposal on repayment of debt underlying the bonds was a disposal ‘to’ the debtor – Reliance on extra-statutory material for construction of the relevant provisions.

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