Ask an expert: Redemption of QCBs and the transitional ER rules

Question: My clients (a married couple) sold their company to a third party company in September 2006 for £300 000 in the form of qualifying corporate bond (QCB) loan notes redeemable at par in three tranches. The capital gain of £250 000 was deferred under TCGA 1992 s 116. The first two loan note tranches of £10 000 each were redeemed on the specified due dates in September 2007 and September 2008. No claim for entrepreneurs’ relief (ER) was made in relation to the redemption in September 2008 as the gain was less than the annual exempt amount. The third tranche of £280 000 which was due for redemption in September 2009 has not yet been redeemed as the purchaser company has experienced cash flow difficulties but my clients hope that...