Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Discounted securities definition

What does Discounted securities mean? A descriptive term used in practice for securities sold for less than a benchmark value. For debt (for example, bonds or notes), it refers to issue or purchase below par so that part or all of the investor’s return is the accretion between the discounted issue price and the redemption price. For equity, it commonly describes shares offered in a rights issue, open offer or placing at a discount to the prevailing market price to incentivise take‑up. The expression is not a defined term in UK or Irish company law and should be distinguished from the UK tax...

Deeply discounted securities and loan relationships: UK corporation tax anti-avoidance post-FA 2015, close company participator loans, non-qualifying territories, RAAR, and the pre-2015 position

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Practice notes

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STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime

The Finance Act 2025 (FA 2025), which obtained Royal Assent on 20 March 2025, legislates to scrap the remittance basis of taxation and bring in a residence-based system from 6 April 2025. It also replaces domicile as the primary determinant of liability to inheritance tax.

Additional reforms include:

Revisions to the Rules that decide excluded property status
Removal of the protected settlements status for offshore trusts
Amendments to overseas workday relief

For details on these developments, see: Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26.

The loan relationships provisions in Part 5 of the Corporation Tax Act 2009 (CTA 2009) contain an anti-avoidance measure concerning so-called deeply Discounted securities (DDS). Where triggered, these rules can delay when a debtor company may claim a corporation tax deduction for the discount. Note that the scope of the DDS regime was markedly narrowed by the Finance Act 2015 (FA 2015)...

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Web page updated on 21/05/2026

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