117 Meaning of “qualifying corporate bond”

117  Meaning of “qualifying corporate bond”

[(A1)     For the purposes of corporation tax “qualifying corporate bond” means . . . any asset representing a loan relationship of a company; and for purposes other than those of corporation tax references to a qualifying corporate bond shall be construed in accordance with the following provisions of this section.]

(1)     For the purposes of this section, a “corporate bond” is a security, as defined in section 132(3)(b)—

(a)     the debt on which represents and has at all times represented a normal commercial loan; and

(b)     which is expressed in sterling and in respect of which no provision is made for conversion into, or redemption in, a currency other than sterling,

and in paragraph (a) above “normal commercial loan” has the meaning which would be given by [section 162 of CTA 2010 if for paragraphs (a) to (c) of subsection (2) of that section there were substituted the words “corporate bonds (within the meaning of section 117 of TCGA 1992)”].

(2)     For the purposes of subsection (1)(b) above—

(a)     a security shall not be regarded as expressed in sterling if the amount of sterling falls to be determined by reference to the value at any time

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