– see also Deep discount securities; Deep gain securities; Deeply discounted securities; Loan relationships

Definition of relevant discounted securities, tax avoidance scheme

Case Law – Astall & Anor v Revenue and Customs Commissioners. [2009] BTC 631

Euroconversion

Legislation/Regulatory – SI 1998/3177 reg. 12

Excluded indexed securities

Commentary – Tax Reporter ¶559-200

Gilt strips

– see Gilt-edged securities

Loan relationships

Chargeable gains

Commentary – Tax Reporter ¶510-900
Case Law – Marren (H.M. Inspector of Taxes) v. Ingles Marren (H.M. Inspector of Taxes) v. Linnell Gordon (H.M. Inspector of Taxes) v. Winton

Connected companies

Commentary – Tax Reporter ¶717-324
HMRC Guidance – CFM35830

Generally

Commentary – Tax Reporter ¶718-150

Qualifying corporate bonds, consequential provisions

Legislation/Regulatory – FA99 s. 66

Redemption

Legislation/Regulatory – FA99 s. 65(8)-(12)

Redemption of loan stock

Case Law – Pike v Revenue and Customs Commissioners. [2013] BTC 1,881

Treasury securities

Commentary – Tax Reporter ¶327-475