伊人直播

ITA07/S987

鈥楨urobonds鈥� are a form of debt security, see CFM11140. They originated in the 1960s when borrowers wanted to raise US dollar finance free from US regulation. With time the market became enormous and issues are made in other currencies. Commercially, a Eurobond is simply a bond which is issued in a market that is different to the home market of the issuer. So, if a UK company wishes to borrow money in Europe, it might issue bonds in a non-sterling currency in the European market. Where, for instance a German company chooses to issue bonds in sterling in the UK market these would be called 鈥榖ulldog bonds鈥�.

These bonds are normally issued in bearer form (CFM11060), normally pay interest once a year, and normally have a life of five years or more. Typically they are held by a clearing house which maintains an electronic ledger of the beneficial owners.

Tax definition of a 鈥榪uoted Eurobond鈥�

鈥楺uoted Eurobond鈥� is a defined term for UK tax purposes and differs from the commercial understanding of the term 鈥楨urobond鈥�. The tax definition is in ITA07/S987 and is important in deciding whether tax should be deducted from any interest paid (see CFM75000 and SAIM9000).

A quoted Eurobond is a security issued by a company which carries a right to interest and is either:

• Listed on a recognised stock exchange; or
• Admitted to trading on a multilateral trading facility operated by a regulated recognised stock exchange.

In this context, a 鈥渞ecognised stock exchange鈥�, is defined in ITA07/S1005. Wherever the exchange is established, the essential requirement is that it is designated as such by the Commissioners for HMRC. For tables of recognised stock exchanges, follow this link.

A 鈥渞egulated recognised stock exchange鈥� is a recognised stock exchange that is regulated in the UK, the European Economic Area, or Gibraltar.

The definition of a 鈥渕ultilateral trading facility鈥� is derived from EU Regulation 600/2014, as set out in ITA07/S987(2)(b).