– see also Corporate bonds

Conditions

Commentary – Tax Reporter ¶559-100
Case Law – Businessman v HM Inspector of Taxes

Conversion from non-qualifying to qualifying

Commentary – Tax Reporter ¶559-600

Conversion from qualifying to non-qualifying

Commentary – Tax Reporter ¶559-600

Corporate venturing scheme

Commentary – Tax Reporter ¶716-340

Debt on a security

Commentary – Tax Reporter ¶511-300

Deemed

Commentary – Tax Reporter ¶559-050 ; Tax Reporter ¶559-100
Case Law – Businessman v HM Inspector of Taxes

Deep gain securities

Commentary – Tax Reporter ¶559-100
Case Law – Businessman v HM Inspector of Taxes

Devolution of death

Commentary – Tax Reporter ¶559-600

Disposals

Case Law – Jenks v. Dickinson (HM Inspector of Taxes). [1997] BTC 286

Earn-out rights

Commentary – Tax Reporter ¶508-050 ; Tax Reporter ¶559-600
HMRC Guidance – CG12060
Case Law – Davis (H.M. Inspector of Taxes) v. Powell ; Marren (H.M. Inspector of Taxes) v. Ingles Marren (H.M. Inspector of Taxes) v. Linnell Gordon (H.M. Inspector of Taxes) v. Winton ; Marson (H.M. Inspector of Taxes) v. Marriage ; O'Brien (H.M. Inspector of Taxes) v. Benson's Hosiery (Holdings) Ltd.

Entrepreneurs' relief

Commentary – Tax Reporter ¶573-330 ; Tax Reporter ¶573-350 ; Tax Reporter ¶573-400

Exchange partly in form of shares

Commentary – Tax Reporter ¶559-500

Excluded indexed securities

Commentary – Tax Reporter ¶559-200

Exemption from chargeable gains

Commentary – Tax Reporter ¶559-000

Gifts to charities

Commentary – Tax Reporter ¶535-600 ; Tax Reporter ¶559-600

Loan notes

Amendment of terms

Case Law – Klincke v Revenue and Customs Commissioners. [2010] BTC 1,644

Generally

Case Law – Businessman v HM Inspector of Taxes (2003) Sp C 374 ; Hancock & Anor v Revenue and Customs Commissioners [2017] BTC 14 ; Harding v Revenue and Customs Commissioners. [2008] BTC 109 ; Harding v Revenue and Customs Commissioners. [2008] BTC 772 ; R (on the application of Weston) v Inland Revenue Commissioners. [2006] BTC 166 ; Weston v Garnett (HM Inspector of Taxes). [2005] BTC 113 ; Weston v Garnett (HM Inspector of Taxes). [2005] BTC 342

Loan relationships

– see Loan relationships

Loss on early redemption

Commentary – Tax Reporter ¶511-300

Meaning

Commentary – Tax Reporter ¶559-100
Case Law – Businessman v HM Inspector of Taxes

Non-chargeable

Commentary – Tax Reporter ¶508-450

Non-sterling debts on a security

Commentary – Tax Reporter ¶559-250

Permanent interest bearing shares

Commentary – Tax Reporter ¶559-100 ; Tax Reporter ¶805-860
Case Law – Businessman v HM Inspector of Taxes

Personal representatives

Commentary – Tax Reporter ¶559-600

Re-investment relief

Commentary – Tax Reporter ¶559-600

Redemption in a currency other than sterling bonds

Case Law – Revenue and Customs Commissioners v Trigg (a partner of Tonnant LLP) [2016] BTC 505

Reorganisations

Commentary – Tax Reporter ¶559-500 ; Tax Reporter ¶559-700 ; Tax Reporter ¶573-330 ; Tax Reporter ¶573-350 ; Tax Reporter ¶573-400

Securities to be treated as

Commentary – Tax Reporter ¶559-250

Transfer of shares within a group in exchange for

Commentary – Tax Reporter ¶559-600

Transfers between revenue and capital

Commentary – Tax Reporter ¶760-500