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we have client -who has bought non UK loan notes and they have

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we have client -who has bought non UK loan notes and they have been sold or rdeemed are these liable to capital gains tax?
Submitted: 2 years ago.
Category: Tax
Expert:  bigduckontax replied 2 years ago.
Hello, I'm Keith and happy to help you with your question.
It is my understanding that any gain made on the sale or redemption of a loan note is liable to Capital Gains Tax. In 14/15 each individual has 11K of Annual Exempt Amount to offset gains.
I do hope I have helped you with your query.
bigduckontax, Accountant
Category: Tax
Satisfied Customers: 3600
Experience: FCCA FCMA CGMA ACIS
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Customer: replied 2 years ago.

Just one question are non UK are deeply discounted securities and treated as income rather than capital gains. how can one find out?

Most of these loan notes are acquired by our client via UBS in Switzerland

Expert:  bigduckontax replied 2 years ago.
As far as I am aware no, there is no indication to that effect. If you are really concerned you could enquire of HMRC for a definite answer.
This is a highly complex area involving possible double taxation were the gains subject to Income Tax which is possible. SIAM3100 [link below] should perhaps be read in conjunction with my answer as well as consulting HMRC. Where redemption has taken place the matter looks pretty clear cut, CGT applies. Where they have been sold the position is less distinctly defined.
http://www.hmrc.gov.uk/manuals/saimmanual/saim3100.htm
Expert:  bigduckontax replied 2 years ago.
Thank you for your support.
Customer: replied 2 years ago.

Thank you

Expert:  bigduckontax replied 2 years ago.
Delighted to have been of assistance.

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