SolvedCG53516 | Debts: satisfied by issuing shares or securities
From HM Revenue & Customs · Capital Gains Manual
One of the most common situations where TCGA92/S251 (3) applies is when a loan is converted into shares. A person who has made a loan to a company may take shares issued by the company and meet the subscription price by reducing the amount of the loan.
However, TCGA92/S251 (3) does not override the ordinary rules of
TCGA92/S126 to TCGA92/S128, which apply to share reorganisations (see CG53516A), or
TCGA92/S132, which applies to the conversion of securities (see CG53517), or
TCGA92/S135, which applies to share exchanges (see CG53518).