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Home / Simons-Taxes /Corporate tax /Part D9 Transfer of rights to income; manufactured payments & repos /Division D9.3 Transfer of rights to income /Transactions in deposits with and without certificates or in debts / D9.305 Disposal of a 'pre 1996' deposit etc
Commentary

D9.305 Disposal of a 'pre 1996' deposit etc

Corporate tax

D9.305 Disposal of a 'pre 1996' deposit etc

Specific rules apply to tax profits or gains on the disposal of a certificate of deposit or the right to receive interest from a deposit with a bank or similar institution where the right to the income/interest was acquired after 6 March 1973 and still held on or after 1 April 19961. In such situations, the income (ie the profits or gains) on the disposal of a 'pre 1996' right is chargeable to corporation tax2.

This treatment is extended to dematerialised certificates (ie a right in pursuance of a deposit) where the arrangements giving rise to the right are made after 16 July 1992 and the right is disposed of or exercised before such time, if any, as a certificate of deposit is issued3.

Neither exempt pension funds nor charities (in so far as the

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