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HMRC internal manual

Capital Gains Manual

Debts: qualifying corporate bonds

TCGA92/S115

Although qualifying corporate bonds are debts on a security, any gain which accrues on their disposal will not be chargeable and any loss will not be allowable. But the disposal may release a gain which was previously ‘held-over’ or ‘frozen’ or deferred if, for instance, the bonds were issued on a share reorganisation or company reconstruction. For further guidance see CG53700+.