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GR Bretten QC v HMRC

In GR Bretten QC v HMRC (TC02604 – 25 March) a barrister (B) acquired six loan notes from a company (O) for their face value of £500 000. The notes carried the right of early redemption for the first 14 days at their issue price or very slightly less. After 14 days they were redeemable at the noteholder’s option for 5% of the issue price (£25 000).  B granted a call option over the notes to a trust of which he was the settlor the life tenant and one of the trustees. This trust exercised the call option received £499 500 from O and was substituted for O as the issuer of the notes. On the same day B gave the notes to a second trust of which he was the settlor and a trustee (but was not the life tenant) so...

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