Michael Ronald Klincke v The Commissioners for HM Revenue and Customs: [2010] UKUT 230 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Newey and Judge Gammie CBE QC on 7 July 2010.

Read the full decision in Michael Ronald Klincke v The Commissioners for HM Revenue and Customs: [2010] UKUT 230 (TCC).

CAPITAL GAINS TAX – securities issued in exchange for shares – whether securities became qualifying corporate bonds on subsequent amendment of terms – yes – whether amendment amounted to a conversion of securities – yes – whether gain on subsequent redemption chargeable to tax – yes – appeal dismissed.

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