Commentary

D9.448 Unrealised interest received by transferee

Corporate tax
Corporate tax | Commentary

D9.448 Unrealised interest received by transferee

Corporate tax | Commentary

D9.448 Unrealised interest received by transferee

Where securities are transferred with unrealised interest, the transferee is only chargeable to income tax in respect of such unrealised interest received by him if1:

  1.  

    (a)     the unrealised interest was in default at the time of transfer; and

  2.  

    (b)     the amount of unrealised interest received exceeds the residual value of the interest.

The residual value of the interest is the value of the right to receive it on the day of acquisition less any unrealised interest previously received by the transferee2.

Any liability in respect of unrealised interest

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