In N Trigg v HMRC [2018] EWCA 17 Civ (18 January 2018) the Court of Appeal found that bonds denominated in sterling but which could be converted into euros in the event that the UK joined the monetary union were qualifying corporate bonds (QCBs) for the purpose of TCGA 1992 s 117.
Mr Trigg’s case was the lead case among nine joint references made by partners in Tonnant LLP (an investment partnership) who had purchased sterling denominated bonds on the secondary market and sold them at a gain. The bonds and the gains were treated in their tax returns as exempt from CGT on the ground that they were QCBs.
Although the bonds were denominated in sterling their terms provided that they would be converted into another currency in the event that the UK adopted the euro as its currency before their redemption. Agreeing with the...
