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HMRC internal manual

Capital Gains Manual

Reorganisations of share capital: introduction: qualifying corporate bonds

Where qualifying corporate bonds (QCBs) are issued by a company as part of a reorganisation of its share capital the ‘no disposal and no acquisition’ treatment described in CG51700 does not apply to the QCBs. Instead a gain or loss on the original shares is computed but is not charged or allowable until the QCBs are disposed of; TCGA92/S116 (5) and TCGA92/S116 (10) see CG51700 and CG53709+.