Revenue Note for Guidance

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Revenue Note for Guidance


Miscellaneous provisions

51 Funding bonds issued in respect of interest on certain debts

(1) “Funding bonds” includes all bonds, stocks, shares, securities and certificates of indebtedness.

(2) The section applies to all debts owing by any Government, public authority, or public institution whatever or wherever and to all debts owing by any body corporate whatever or wherever.

(3) The issue of funding bonds to a creditor in respect of any liability to pay interest on a debt is treated for tax purposes as if it were the payment of the amount of interest equal to the value of the bond at the time of issue. As a corollary, the redemption of the bond is not treated for tax purposes as a payment of interest.

Relevant Date: Finance Act 2021