Income Tax (Trading and Other Income) Act 2005 section 80

Discounted securities: deemed transfers of strips on 5th April

Section 80 is a transitional provision that preserves the tax treatment of government security strips that were deemed to have been transferred on 5th April 2005, ensuring continuity when the old rules under the Finance Act 1996 were replaced by ITTOIA 2005.

• Anyone deemed to have transferred a strip on 5th April 2005 under the old Finance Act 1996 rules is treated as having re-acquired it on 6th April 2005 at the same value
• The deemed transfer and re-acquisition are treated as if they were carried out under section 445(2) and (3) of ITTOIA 2005, which governs strips of government securities
• This ensures no tax charge or relief is lost or duplicated as a result of the changeover from the old legislation to the new Act
• The Treasury's power under section 452 to modify the deeply discounted securities rules for strips extends to this transitional provision as well