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Contents

Official guidance
Capital Gains Manual

CG53400P · Shares and securities: securities: debts

  • CG53400 · Shares and securities: debts: what is a debt?
  • CG53405 · Securities: debts: capital gains treatment of debts
  • CG53406 · Securities: debts: CG treatment of debts: - gilt-edged securities
  • CG53407 · Securities: debts: CG treatment of debts: security: QCBs
  • CG53408 · Securities: debts: CG treatment of debts: - other debts
  • CG53410 · Securities: debts: layout of instructions
  • CG53420 · Securities: debts: definition of debt on a security
  • CG53422 · Debt on a security: Tax Case guidance
  • CG53423 · Debt on a security: W T Ramsay Ltd v CIR
  • CG53424 · Debt on a security: House of Lords decision: marketability
  • CG53425 · Shares and securities: debts: debt on a security: essential characteristics of
  • CG53431 · Debt on security: when conditions satisfied
  • CG53433 · Debt on security: exchange gains
  • CG53434 · Debt on security: documentation
  • CG53435 · Debt on security: loan stock or similar security
  • CG53436 · Debt on security: loan accounts
  • CG53440 · Debt on security: other debts deemed to be securities
  • CG53441 · Other debts deemed to be securities: debts acquired on share exchanges
  • CG53444 · Other debts deemed to be securities: loan relationships of companies
  • CG53446 · Other debts deemed to be securities: excluded indexed securities
  • CG53450 · Debt on security: debts on a security: general
  • CG53451 · Debts which are debts on a security: losses: disposals: connected persons
  • CG53470 · Debts which are not debts on a security: introduction
  • CG53471 · Debts which are not debts on a security: original creditor
  • CG53473 · Debts not debts on a security: foreign currency bank accounts
  • CG53480 · Debts not debts on a security: subsequent creditor
  • CG53485 · Debts not debts on a security: settled property when created
  • CG53490 · Securities: debts: general points: situation of the debt
  • CG53495 · Securities: debts: general points: bundle of rights
  • CG53500 · Securities: debts: general points: payments under guarantee
  • CG53510 · Securities: debts: general points: satisfied by acquisition of property
  • CG53511 · Debts: satisfied by acquisition of property: disposal by debtor
  • CG53512 · Debts: debt satisfied by acquisition of property: disposal by creditor
  • CG53513 · Debts: satisfied by acquisition of property: acquisition by creditor
  • CG53514 · Debts: satisfied by acquisition of property: Section 251(3) adjustment
  • CG53516 · Debts: satisfied by issuing shares or securities
  • CG53516A · Debts: satisfied by issuing shares or securities: share reorganisations
  • CG53517 · Debts: satisfied by issuing shares or securities: conversion of securities
  • CG53518 · Debts: satisfied by issuing shares or securities: share exchanges
  • CG53530 · Securities: debts: company purchase of own debentures
  • CG53535 · Securities: debts: substitution of debtor
  • CG53401 · Securities: debts: what is a debt: secured debts
  • CG53402 · Securities: debts: what is a debt: documentation
  • CG53403 · Securities: debts: introduction: what is a debt?
  • CG53426 · Debt on a security: essential characteristics of: held as an investment
  • CG53427 · Debt on a security: essential characteristics of: sold at a profit
  • CG53428 · Debt on a security: essential characteristics of: structure of permanence
  • CG53429 · Debt on security: essential characteristics of: repayment at short notice
  • CG53430 · Debt on security: essential characteristics of: events of default
  • CG53432 · Debt on security: when conditions satisfied: changes in terms
  • CG53442 · Other debts deemed to be securities: debts acquired on share exchanges
  • CG53445 · Other debts deemed to be securities: loan relationships of companies
  • CG53472 · Debts which are not debts on a security: original creditor: losses
  • CG53481 · Debts not debts on a security: subsequent creditor: losses
  • CG53482 · Debts not debts on a security: subsequent creditor: companies
  1. Shares and securities: securities: debts: contents
  2. Debt on security: loan stock or similar security

CG53435 | Debt on security: loan stock or similar security

From HM Revenue & Customs · Capital Gains Manual

In Ramsay Lord Wilberforce did not regard it as necessary to decide whether the loan L2 was, in fact, within the meaning of loan stock'. He observed that TCGA92/S132 (3)(b) includes within security' any similar security’ to loan stock: in my opinion these words cover the facts. This was a contractual loan, with a structure of permanence such as fitted it to be dealt in …’ (page 190). Lord Fraser took a similarly broad approach in his judgment (page 194).

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