Bonds with euro forex clause were QCBs

Trigg v HM Revenue & Customs [2018] EWCA 17 Civ considered an appeal by Mr Nicholas Trigg, a lead case among nine joint references to the First Tier Tribunal (FTT) by various partners in a limited liability partnership, Tonnant LLP, who had purchased sterling denominated bonds on the secondary market at an undervalue with a view to their retention until maturity or disposal at a profit.

The bonds were disposed of and the gains were treated as exempt from capital gains tax (CGT) on the ground that they were qualifying corporate bonds (QCBs) within the meaning of Taxation of Chargeable Gains Act 1992 (TCGA 1992), s117.