Capital gains tax – redemption of qualifying corporate bonds (QCBs) -
scheme to avoid the application of s 116 TCGA to a conversion of non-
QCBs into QCBs – s 116(1)(b) and s 132 - whether a single transaction of non-
QCBs and QCBs into QCBs or two separate transactions – whether the conversion
and redemption should be treated as a single composite transaction of the
disposal/redemption of non-QCBs – the Ramsay principle.