ANNEX 1:: MINOR CHANGES IN THE LAW MADE BY THE BILL This change has no implications for the amount of tax due, who pays it or when. It affects (in principle and in practice) only administrative matters.
Change 149: Deduction of tax: meaning of “qualifying certificate of deposit” and “qualifying uncertificated eligible debt security unit”: sections 985 and 986
This change aligns the terms of the repayment condition in the definitions of “qualifying certificate of deposit” and “qualifying uncertificated eligible debt security unit” with the terms of the repayment condition in the definition of “qualifying time deposit”.
Under the source legislation (sections 349(4) and 482(6) of ICTA), the issuer of any of these two instruments must pay an amount of not less than £50,000 (or equivalent if in a foreign currency) “after a period of not more than five years beginning with the date on which the deposit is made”.
The source legislation is not clear about whether this means that the amount must be repaid in one tranche at a specified time. But in practice, whenever these instruments are issued, they are issued on the basis that the amount is payable in one tranche at a specified time within five years of the date of the deposit being made, in line with the position for qualifying time deposits.