Gains on qualifying corporate bonds (QCB) are exempt from tax on chargeable gains and a loss is not an allowable loss, this is detailed further below1. Different definitions of a QCB apply for corporation tax and capital gains tax purposes as detailed below.
Qualifying corporate bonds—exemption
A gain arising on the disposal of an asset which, at the time of disposal is a QCB is not a chargeable gain, and a loss on such a disposal is not an allowable loss2.
The exemption not only applies to qualifying corporate bonds, but also to any option or outstanding obligation under contract to acquire or dispose of them3. Furthermore, the exemption applies to a gain that would otherwise be chargeable on the occasion when a taxpayer closes out of a contract to acquire or dispose of qualifying corporate bonds by entering into another contract with reciprocal obligations4.
As a result of this exemption, special rules apply for corporate reorganisations involving qualifying corporate bonds. See D6.111.
Qualifying corporate bond
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Web page updated on 24 Aug 2024 14:40