Commentary

D9.525 Purpose of legislation

Corporate tax
Corporate tax | Commentary

D9.525 Purpose of legislation

Corporate tax | Commentary

Corporate strips

D9.525 Purpose of legislation

The rules on deeply discounted securities were extended to apply to strips of bonds issued other than by governments (referred to as 'corporate strips') acquired after 1 December 2004, unless acquired under an agreement entered into before that date. The initial legislation was contained in FA 19961. From 6 April 2005, FA 1996 was repealed as part of the re-write process, and corporate strips now fall under ITTOIA 20052.

These provisions were essentially an anti-avoidance measure designed to counter particular schemes involving these types of strips. The schemes involved taking normal interest bearing securities

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