Capital gains tax – Tax avoidance scheme. Parliament's intention had been that each security converted into a qualifying corporate bonds (QCBs) should be viewed as a separate conversion, which amounted regarding the conversion in the present case as consisting of two conversions, one of QCBs and one of non-QCBs. Accordingly, the Supreme Court, in dismissing the appellant taxpayers' appeal, rejected their contention that the redemption of loan notes fell outside the charge to capital gains tax by virtue of the exemption in s 115 of the Taxation of Chargeable Gains Act 1992 for disposals of QCBs on the basis that there had been a single conversion.