In HMRC v N Trigg [2016] UKUT 165 (12 April 2016) the UT found that a condition applying to corporate bonds which provided for their redemption in euros in the event that that the euro became the currency of the UK prevented them from being qualifying corporate bonds (QCBs).
The issue was whether corporate bonds purchased by Mr Trigg were QCBs so that they were exempt from CGT under TCGA 1992 s 117. The dispute concerned the effect of two types of clauses which addressed the possibility of the euro becoming the currency of the UK. HMRC contended that these had the effect that the bonds had a provision for conversion or redemption in a currency other than sterling. Mr Trigg argued however that in the circumstances covered by the two clauses the euro would not be a ‘currency other than sterling’...
