Part 4Savings and investment income

Chapter 8Profits from deeply discounted securities

Special rules for strips of government securities

444Meaning of “strip” in Chapter 8

1

In this Chapter “strip”, in relation to any stock or bond (“the underlying security”), means a security which—

a

meets conditions A to C,

b

if it was acquired after 26th March 2003, was issued by or on behalf of the government of any territory, and

c

if it was acquired on or before that date, was issued under the National Loans Act 1968 (c. 13) in a case where the underlying security was itself a gilt-edged security.

2

Condition A is that the security is issued for the purpose of representing the right to or of securing—

a

a payment corresponding to a payment of interest or principal remaining to be made under the underlying security, or

b

two or more payments each corresponding to a payment to be so made.

3

Condition B is that the security is issued in conjunction with the issue of one or more other securities which, together with that security—

a

represent the right to, or

b

secure,

payments corresponding to every payment remaining to be made under the underlying security.

4

Condition C is that the security is not itself a security which—

a

represents the right to, or

b

secures,

payments corresponding to a part of every payment remaining to be made under the underlying security.

5

After the balance has been struck for a dividend on any underlying security, a payment to be made in respect of that dividend is treated for the purposes of conditions A to C as not being a payment remaining to be made under the underlying security.

F16

Nothing in this section affects the meaning of the expression “corporate strip” in this Chapter (see section 452E).