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Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.15 Accrued income scheme /Accrued income scheme—transactions treated as transfers / E1.1511 Accrued income scheme—variable-rate securities
Commentary

E1.1511 Accrued income scheme—variable-rate securities

Personal and employment tax

Without special provisions, it would be possible to avoid effective application of the accrued income scheme legislation by the issue of securities with widely varying rates of interest over the period between issue and redemption. For example, they might carry an interest rate for the first two years at two per cent, for the next two years at 20% and at 10% thereafter. Thus a sale cum-div shortly before the end of the second year would result in a charge on the vendor (based on a two per cent interest payment) of a very small accrued income profit ((AIP), see E1.1502, whereas the value of the securities is enhanced by the prospect of a high interest

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