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A client owned shares in a trading company which, some ten years ago, were sold for cash and non-qualifying corporate bonds. The loan note agreement says that 'the company hereby covenants that unless previously redeemed or repaid under any of the provisions of this instrument, the notes will be repaid at par, together with accrued interest on the tenth anniversary of the date of issue'.
The loan note agreement makes no provision for extending the period, which ended on 27 March 2006.
The actual repayment did not take place until May 2006.
A client owned shares in a trading company which some ten years ago were sold for cash and non-qualifying corporate bonds. The loan note agreement says that 'the company hereby covenants that unless previously redeemed or repaid under any of the provisions of this instrument the notes will be repaid at par together with accrued interest on the tenth anniversary of the date of issue'.
The loan note agreement makes no provision for extending the period which ended on 27 March 2006.
The actual repayment did not take place until May 2006.
Could readers advise me as to which year the disposal should fall for capital gains tax purposes?
Query T16 861 — Delay.
Reply by Venta Belgarum:
The position is different for the principal than for the interest. For capital gains tax purposes the due date of...
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