A limited liability partnership was carrying on a business when loan notes were transferred to it, so the transfers were capital contributions rather than disposals of the loan notes. 

The appellants were a company (GCH), a limited liability partnership (LLP), and three family trusts created by an individual (GH), who was trustee of the trusts and a director and shareholder of GCH. In June 2010, the appellants held shares in another company (T). Following professional advice about the sale of shares in T, the LLP had been incorporated on 26 August 2010. The two initial members were H (as trust nominee) and GCH. The LLP bought five holdings of quoted company shares. On 1 September 2010, the LLP sold two of those holdings. On 24 September 2010, T was taken over by another company (P). Under the takeover terms, the appellants exchanged shares in T for loan notes issued by P. On 18 May 2011, GH (as a trust nominee) was admitted as an LLP member. The LLP members