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HMRC internal manual

Capital Gains Manual

Groups: indexation allowance restriction: debts on a security

The provisions do not apply to a simple debt (that is, a debt which is not a debt on a security). This is because on the disposal of a simple debt by

  • THE ORIGINAL CREDITOR neither a chargeable gain nor an allowable loss can accrue, see CG53471
  • A TRANSFEREE FROM THE ORIGINAL CREDITOR, no allowable loss can accrue where the transferor and the transferee, or all the transferors and transferees in a sequence of transfers, are connected persons, see CG53480+.