Section 151U: Treatment of bond-holder and bond-issuer

Taxation of Chargeable Gains Act 1992 · 1992 c. 12View on legislation.gov.uk

Part IV: Shares, securities, options etc. — Chapter 4: Alternative finance arrangements

This section applies for the purposes of this Act and any other enactment about capital gains tax and irrespective of the position for other purposes.

The bond-holder under investment bond arrangements is not treated as having a legal or beneficial interest in the bond assets.

The bond-issuer under such arrangements is not treated as a trustee of the bond assets.

Gains accruing to the bond-issuer in connection with the bond assets are gains of the bond-issuer and not of the bond-holder (and do not arise to the bond-issuer in a fiduciary or representative capacity).

Payments made by the bond-issuer by way of redemption payment or additional payment are not made in a fiduciary or representative capacity.

The bond-holder is not entitled to relief for capital expenditure in connection with the bond assets.

Expressions used in this section have the same meaning as in section 151N.

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Reuse reviewed 21 August 2026 under Open Government Licence v3.0.