SCHEDULES

SCHEDULE 15U.K. Loan relationships: savings and transitional provisions

Part IIU.K. Income tax and capital gains tax

Qualifying indexed securitiesU.K.

27(1)This paragraph applies where—U.K.

(a)on 5th April 1996 any person (“the relevant person”) held a qualifying indexed security;

(b)that person did not dispose of that security on that date and does not fall (apart from by virtue of this paragraph) to be treated for the purposes of the 1992 Act as having made a disposal of it on that date; and

(c)a relevant event occurs.

(2)For the purposes of this paragraph a relevant event occurs on the first occasion after 5th April 1996 when the relevant person, or a person to whom that person has made a disposal of the security within marriage [F1or civil partnership], falls to be treated for the purposes of the 1992 Act as making a disposal (otherwise than within marriage [F1or civil partnership]) which is—

(a)a disposal of the security in question; or

(b)a disposal of any such asset as falls to be treated for the purposes of that Act as the same as that security.

(3)The amount of any chargeable gain or allowable loss which would have been treated as accruing to the relevant person if—

(a)he had made a disposal of the asset on 5th April 1996, and

(b)that disposal had been for a consideration equal to the market value of the asset,

shall be brought into account as one accruing to the person who makes the disposal constituting the relevant event in the year of assessment in which that event occurs.

Textual Amendments

F1Words in Sch. 15 para. 27(2) inserted (5.12.2005) by The Tax and Civil Partnership Regulations 2005 (S.I. 2005/3229), regs. 1(1), 130