The conditions for a security to be a ‘qualifying corporate bond’ (QCB) depend upon whether the holder is a company.

For corporation tax purposes, a QCB means any asset representing a ‘loan relationship’ of a company (see ¶717-010ff.) (TCGA 1992, s. 117(A1)).

Where the holder of the security is not a company, in order to determine whether the security is a QCB, it is first necessary to consider whether it is a ‘corporate bond’ and then whether it satisfies the qualifying conditions (see below).

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