SCHEDULE 15 Loan relationships: savings and transitional provisions
Part II Income tax and capital gains tax
Transitional in relation to qualifying corporate bonds
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(1)
This paragraph applies where—
(a)
any person holds any asset on and immediately after 5th April 1996;
(b)
that asset is one which came to be held by that person as a result of a transaction to which section 127 of the 1992 Act applies; and
(c)
that asset falls from 5th April 1996 to be treated as a F1deeply discounted security but is neither a qualifying indexed security nor such that it would have fallen to be treated as a qualifying corporate bond in relation to any disposal of it on that date.
(2)
Section 116 of the 1992 Act (reorganisations etc. involving qualifying corporate bonds) shall have effect as if—
(a)
there had been a transaction on 5th April 1996 by which the person holding the asset had disposed of it and immediately re-acquired it;
(b)
the asset re-acquired had been a qualifying corporate bond; and
(c)
the transaction had been a transaction to which section 127 of the 1992 Act would have applied but for section 116(5) of that Act.