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Conversion effect

27 January 2015 / Pete Miller
Issue: 4486 / Categories: Comment & Analysis , Capital Gains

The First-tier Tribunal’s decision in the corporate bonds case of Trigg


  • A partnership claimed a gain on the sale of corporate bonds was not liable to capital gains tax.
  • The bonds contained euro conversion clauses.
  • The meaning of sterling must mean the UK pound sterling.
  • It would be illogical for bonds with a euro conversion clause not to be qualifying corporate bonds when sterling denominated bonds that would be converted automatically on the adoption of the euro as the UK’s currency would not.

Nicholas Trigg was part of a partnership which had bought undervalued bonds on the market. Six of those bonds had been sold and he along with the other members of the partnership claimed that no capital gains arose.

This was on the basis that the bonds were qualifying corporate bonds and therefore exempt from capital gains tax...

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