Commentary

D9.501 Scope of charge to tax

Corporate tax
Corporate tax | Commentary

D9.501 Scope of charge to tax

Corporate tax | Commentary

Division D9.5     Deeply discounted securities

Prepared by
RUTH NEWMAN, LLB (Hons), MA, CTA

For updates affecting this Division please see Part D0 Updates

Taxation of deeply discounted securities

D9.501 Scope of charge to tax

A security is issued at a discount if the amount payable on redemption exceeds the issue price. This Division describes a charge to income tax on profits on a disposal (see D9.504) of deeply discounted securities ie (previously called relevant discounted securities), ie securities on which the discount exceeds a specified proportion of the amount payable on redemption. For companies, such profits are within the loan

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