Deeply discounted securities

Produced by a Tolley Personal Tax expert

Personal Tax

Guidance

STOP PRESS: The remittance basis is to be abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in Finance Bill 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

A security is issued at a discount if the amount payable on redemption exceeds the issue price. The profits on disposal of deeply discounted securities (DDS) are chargeable to income tax rather than capital gains tax. An income tax profit arises where the discount exceeds a specified proportion of the amount payable on redemption. Losses are not usually allowable.

The profit is classed as savings income for the income tax calculation, and so the savings income tax rates apply, including the starting rate for savings and the savings nil rate band. See the Taxation of savings income guidance note for details.

The current rules on DDS apply for

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