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HMRC internal manual

Capital Gains Manual

Debt on a security: Tax Case guidance

The meaning of debt on a security has been considered by the Courts a number of times. The leading case is W T Ramsay Ltd v CIR 54TC101. In that case the House of Lords acknowledged this is a difficult subject. Lord Wilberforce said `Many learned judges have found it baffling both on the statutory wording and as to the underlying policy’. These instructions approach these problems by looking at the decision in Ramsay and considering what guidance can be drawn from the speeches of Lords Wilberforce and Fraser.