HC Deb 17 July 1986 vol 101 cc1300-1

Amendments made: No. 113, in page 191, line 2, leave out `(5)' and insert `(6)'.

No. 114, in page 191, leave out from beginning of line 3 to end of line 8 on page 192 and insert— '(2) In sub-paragraphs (2) and (3) for "the unrealised interest" there shall be substituted "amount A". (3) For sub-paragraph (4) there shall be substituted— (4) Where the transferee receives an amount by way of the unrealised interest (amount B) and that amount falls to be taken into account in computing tax charged for the chargeable period in which it is received, it shall for the purposes of the Tax Acts be treated as reduced by an amount (amount C) equal to—

  1. (a) nil, if amounts have been previously received by the transferee by way of the unrealised interest and their aggregate is equal to or greater than the value (on the day of the transfer to the transferee) of the right to receive the unrealised interest,
  2. (b) amount B, if that value is equal to or greater than amount B (aggregated with other amounts previously so received, if any),
  3. (c) that value, if no amount has been previously so received and that value is less than amount B, or
  4. (d) so much of that value as exceeds the aggregate of amounts previously so received, in any other case."
(4) In sub-paragraph (7) for "the amount of the unrealised interest" there shall be substituted "amount A". (5) In sub-paragraph (7A) for "the amount of the unrealised interest" there shall be substituted "amount C". (6) The following shall be substituted for sub-paragraph (8)— (8) In this paragraph 'amount A' means, in case where the transferor acquired the securities by a transfer on or after 28th February 1986 with the right to receive unrealised interest,—
  1. (a) an amount equal to amount D less amount E, or
  2. (b) if amount D is equal to or less than amount E, nil
 (9) In this paragraph 'amount A' means, in a case riot falling within sub-paragraph (8) above, an amount equal to amount D. (10) In this paragraph 'amount D' is an amount equal to the value (on the day of the transfer by the transferor) of the right to receive the unrealiaed interest. (11) In this paragraph 'amount E' means, in a case where the transferor (as transferee) has received in respect of the securities an amount or amounts falling within sub-paragraph (4) above,—
  1. (a) an amount equal to amount F less the total received, or
  2. (b) if amount F is equal to or less than the total received, nil.
 (12) In this paragarph 'amount E' means, in any other case, an amount equal to amount F. (13) In this paragraph 'amount F' means an amount equal to the value (on the day of the transfer to the transferor) of the right to receive the unrealised interest. (14) In determining for the purposes of this paragraph which securities of a particular kind a person has transferred, he is to be taken to have transferred securities of that kind which he acquired later before securities of that kind which he acquired earlier. (15) Where the unrealised interest is payable in a currency other than sterling—
  1. (a) any amount received by way of the interest is for the purpose of this paragraph the sterling equivalent on the day it is received of the amount it would he apart from this sub-paragraph, and
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  2. (b) the value (on the day of a transfer) of the right to receive the interest is for the purposes of this paragraph the sterling equivalent (on that day) of the value it would be apart from this sub-paragraph;
and for this purpose the sterling equivalent is to be calculated by reference to the London closing rate of exchange for the day concerned.".'.—[Mr. MacGregor.]

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