Although, as we have seen,318 the automatic tests are full of uncertainties and, as we shall see,319 so too are the UK ties, the provision of day count bands will allow those who wish to be non-resident to plan their trips to the UK more securely than they have been able to do in the past. What is likely to be a fairly typical situation is set out in Example 21.1.

Example 21.1

The Situation

Mr A had lived in the UK all of his life. In 2010 he sold his trading company for loan notes in the acquiring company. The loan notes were to be redeemed on 30 June 2014 resulting in a gain of £25 million accruing to Mr A under TCGA 1992, s. 116(10)(b) .

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