Conversion of non-QCBs to QCBs tax avoidance scheme fails (First-tier Tribunal) | Practical Law

Conversion of non-QCBs to QCBs tax avoidance scheme fails (First-tier Tribunal) | Practical Law

The First-tier Tribunal has ruled that variations made to the terms of non-qualifying corporate bonds were effective to convert them to qualifying corporate bonds but, applying the Ramsay principle, were unsuccessful in reducing their market value at conversion (William Blumenthal v HMRC [2012] UKFTT 497 (TC)).       

Conversion of non-QCBs to QCBs tax avoidance scheme fails (First-tier Tribunal)

Practical Law UK Legal Update Case Report 7-521-1433 (Approx. 10 pages)

Conversion of non-QCBs to QCBs tax avoidance scheme fails (First-tier Tribunal)

by PLC Tax
Published on 03 Sep 2012 • United Kingdom
The First-tier Tribunal has ruled that variations made to the terms of non-qualifying corporate bonds were effective to convert them to qualifying corporate bonds but, applying the Ramsay principle, were unsuccessful in reducing their market value at conversion (William Blumenthal v HMRC [2012] UKFTT 497 (TC)).