(a) they are treated for the purposes of section 830 (meaning of "relevant foreign income") as arising from a source outside the United Kingdom, and

(b) subsection (1) is subject to Part 8 (foreign income: special rules).

A × 0.5% × Y,

where Y is the number of years in the redemption period or 30, whichever is the lower.
 

section 431 (excluded occasions of redemption),

section 432 (securities which are not deeply discounted securities),

sections 434 to 436 (securities issued in separate tranches), and

section 443(1) (strips of government securities).

(a) the security may be redeemed on the occasion at the option of a person other than its holder,

(b) the security is issued to a person who is not connected with the issuer, and

(c) the obtaining of a tax advantage by any person is not the main benefit, or one of the main benefits, that might have been expected to accrue from the provision in accordance with which the security may be redeemed on the occasion.

(a) the security may be redeemed on the occasion as the result of an exercise of an option that is exercisable only on the occurrence of-

(i) an event adversely affecting the holder (see subsection (8)), or

(ii) a default by any person, and

(b) as at the time of the security's issue it appears unlikely that the option will be exercisable on the occasion.

(a) the only reason that a security is not a deeply discounted security is that an occasion on which it may be redeemed is ignored because the third-party option conditions are met, and

(b) at some time after its issue the security is acquired by, or its holder becomes, a person connected with the issuer,

(a) a security which is only a deeply discounted security because it was issued to a person connected with the issuer and so fails to meet the condition specified in subsection (2)(b), or

(b) a security within subsection (5),

(a) shares in a company,

(b) gilt-edged securities that are not strips,

(c) life assurance policies, and

(d) capital redemption policies.

(a) the value of chargeable assets of a particular description, or

(b) an index of the value of such assets.

(a) the period beginning with the date of issue and ending with the date of redemption, or

(b) a period which is or includes almost all that period and only differs from it for purposes connected with giving effect to a valuation in relation to rights or liabilities under the security.

(a) the asset is an asset of the person,

(b) the person is not entitled to the exemption conferred by section 100 of TCGA 1992 (exemption for authorised unit trusts etc.),

(c) disposal of the asset by the person would not be treated for income tax purposes as a disposal in the course of a trade, profession or vocation, and

(d) section 116(10) of TCGA 1992 is ignored (chargeable gains on subsequent disposals of qualifying corporate bonds acquired in reorganisations, conversions and reconstructions).

(a) neither the retail prices index nor any similar general index of prices published by the government of a territory or by an agent of such a government is an index of the value of chargeable assets, and

(b) "redemption", in relation to a security, does not include its redemption on an occasion which is to be ignored under section 431(1) (excluded occasions of redemption).

(a) the rule in section 435 applies to securities in later issues under it, and

(b) the rule in section 436 does not apply to any securities issued under it.

(a) that the securities were issued to a person connected with the issuer and so fail to meet the condition specified in section 431(2)(b), and

(b) that such a person has acquired or become the holder of the securities and so section 431(5) applies to them.

(a) to its redemption,

(b) to its transfer by sale, exchange, gift or otherwise, including a transfer treated as made by subsection (3), and

(c) so far as not covered by paragraph (a) or (b), to its conversion under its terms into shares in a company or other securities (including other deeply discounted securities).

(a) in the case of a disposal within subsection (1)(a), the person entitled as the security's holder to any payment on the disposal,

(b) in the case of a disposal within subsection (1)(b), the transferor, and

(c) in the case of a disposal within subsection (1)(c), the person who would be entitled as the security's holder to any payment on the disposal, if such a payment were made.

(a) a transfer or acquisition of a deeply discounted security is made under an agreement, and

(b) the transferee or the person making the acquisition becomes entitled to the security at the time the agreement is made.

(a) the amount the person paid to acquire the security, and

(b) incidental expenses within subsection (4).

(a) a transfer made otherwise than by a bargain at arm's length,

(b) a transfer between connected persons,

(c) a transfer for a consideration which is not wholly in money or money's worth,

(d) a transfer treated as made by section 437(3) (death), and

(e) a transfer by personal representatives to a legatee.

(a) on a testamentary disposition, or

(b) on an intestacy or partial intestacy.

(a) a transfer within section 440(2), and

(b) a conversion of a deeply discounted security into other deeply discounted securities which counts as its disposal under section 437(1).

(a) the market value, immediately before the issue, of the right to be issued with the security in accordance with the terms of the qualifying earn-out right, and

(b) any amount payable for the issue in accordance with those terms.

(a) the transfer by the person on whom the right is conferred of shares in or debentures of a company, or

(b) the transfer of the whole or part of-

(i) a business carried on by that person, or by that person and others in partnership, or

(ii) an interest in such a business.

(a) a right to be issued with securities of another company, or

(b) a right which is capable of being discharged in accordance with its terms by the issue of such securities.

(a) section 445 (strips of government securities: acquisitions and disposals),

(b) section 446 (strips of government securities: relief for losses),

(c) section 447 (restriction of profits on strips by reference to original acquisition cost),

(d) section 448 (restriction of losses on strips by reference to original acquisition cost),

(e) section 449 (strips of government securities: manipulation of acquisition, transfer or redemption payments),

(f) section 450 (market value of strips etc.), and

(g) section 451 (market value of strips etc. quoted in foreign stock exchange lists).

(a) meets conditions A to C,

(b) if it was acquired after 26th March 2003, was issued by or on behalf of the government of any territory, and

(c) if it was acquired on or before that date, was issued under the National Loans Act 1968 (c. 13) in a case where the underlying security was itself a gilt-edged security.

(a) a payment corresponding to a payment of interest or principal remaining to be made under the underlying security, or

(b) two or more payments each corresponding to a payment to be so made.

(a) represent the right to, or

(b) secure,

(a) represents the right to, or

(b) secures,

where-

A is the market value of the underlying security at the time of the exchange,

B is the market value of the strip at that time, and

C is the total of the market values at that time of all the strips received in the exchange.
 

(a) a person who holds a strip of a security on 5th April in any tax year is treated as having transferred the strip on that day, and

(b) an amount equal to its market value on that day is treated as payable on the transfer.

(a) the consolidation of a strip of a security with other such strips into a single security is a disposal of the strip by the person consolidating it (whether or not it would be apart from this subsection), and

(b) an amount equal to the market value of the strip at the consolidation is treated as payable on the disposal.

(a) the person disposes of the strip, and

(b) the amount the person paid for the strip, ignoring any incidental expenses incurred in connection with the acquisition, exceeds the amount payable on the disposal, ignoring any incidental expenses incurred in connection with the disposal.

(a) section 448 (restriction of losses on strips by reference to original acquisition cost),

(b) section 449 (strips of government securities: manipulation of acquisition, sale or redemption payments), and

(c) section 458(2) (strips held by non-UK resident trustees).

(a) a person makes a profit on the disposal of a strip (apart from this section), and

(b) the person's original acquisition cost for the strip (see subsection (4)) exceeds the amount that falls to be brought into account as the amount paid by the person to acquire the strip in determining the amount of the profit.

(a) disposals under section 445(2) (other than the disposal in question), and

(b) acquisitions under section 445(3).

(a) a person makes a loss on the disposal of a strip (apart from this section), and

(b) the person's original acquisition cost for the strip exceeds the amount that falls to be brought into account as the amount payable on the disposal of the strip in determining the amount of the loss.

A is the person's original acquisition cost for the strip, and

B is the amount that falls to be brought into account as the amount payable on the disposal of the strip in determining the amount of the loss.
 

(a) as a result of a scheme or arrangement an amount referred to in subsection (2)(a), (b) or (c) differs from the market value of a strip in a way specified in that subsection, and

(b) the obtaining of a tax advantage by any person is the main benefit, or one of the main benefits, that might have been expected to accrue from, or from any provision of, the scheme or arrangement.

(a) the amount paid by a person in respect of the acquisition of the strip is or was more than the market value at the time of the acquisition,

(b) the amount payable to a person on transferring the strip is less than the market value at the time of the transfer, or

(c) on redemption of the strip the amount payable to a person, as the person holding the strip, is less than the market value on the day before redemption.

(a) determining the market value at any time of a strip for the purposes of this Chapter, and

(b) determining the market value at any time of a security exchanged for strips of that security for the purposes of section 445(1).

(a) the lower of the two figures shown in that List for the strip or security for that day, plus

(b) one-quarter of the difference between those two figures.

(a) its market value on the latest previous day on which the Stock Exchange is open, and

(b) its market value on the earliest subsequent day on which the Stock Exchange is open.

(a) any strip, or

(b) any security exchanged for strips of that security.

(a) subsection (2) or (3), or

(b) any provision of section 451.

(a) make different provision for different cases, and

(b) contain such incidental, supplemental, consequential and transitional provision and savings as the Treasury consider appropriate.

(a) is a security, or a strip of a security, issued by or on behalf of the government of a territory outside the United Kingdom, and

(b) is not quoted in The Stock Exchange Daily Official List, but

(c) is quoted in a foreign stock exchange list.

(a) the lower of the two figures shown in that list for the strip or security for that day, plus

(b) one-quarter of the difference between those two figures.

(a) its market value on the latest previous day on which that exchange is open, and

(b) its market value on the earliest subsequent day on which that exchange is open.

(a) any such list published for a foreign stock exchange in the territory of the issuing government is to be used for the purposes of this section in preference to any other such list, and

(b) any such list published for a foreign stock exchange which is regarded as the major exchange in that territory for strips or securities is to be used for those purposes in preference to any other such list.

"foreign stock exchange" means a recognised stock exchange in a territory outside the United Kingdom on which strips are traded,

"foreign stock exchange list" means any publication which performs in the case of a foreign stock exchange a function equivalent, or broadly similar, to that performed by The Stock Exchange Daily Official List in relation to strips, and

"issuing government" means the government which issued the security mentioned in subsection (1)(a).

(a) providing for relief for losses on the disposal, and

(b) calculating the amount of profits chargeable under this Chapter on the disposal or the losses for which such relief may be given.

A is the amount the person paid for the securities, excluding any incidental expenses incurred in connection with the acquisition, and

B is the amount payable on the disposal, excluding any incidental expenses incurred in connection with the disposal.

(a) the amount paid by the person to acquire the security, and

(b) the incidental expenses incurred by that person in connection with the disposal or the acquisition.

section 446 (strips of government securities: relief for losses), and

section 454 (listed securities held since 26th March 2003: relief for losses).