CG53422 - Debt on a security: Tax Case guidance
The meaning of debt on a security has been considered by the Courts a number of times. The leading case is W T Ramsay Ltd v CIR 54TC101. In that case the House of Lords acknowledged this is a difficult subject. Lord Wilberforce said `Many learned judges have found it baffling both on the statutory wording and as to the underlying policy鈥�. These instructions approach these problems by looking at the decision in Ramsay and considering what guidance can be drawn from the speeches of Lords Wilberforce and Fraser.