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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Debt on security: when conditions satisfied

You should consider whether any debt amounts to the debt on a security by reference to the circumstances prevailing at the time the debt was created. For example, you should consider whether a rate of interest is commercial by reference to the market conditions at the time the debt was created. Thus, you may take into account any market opinion, at the time the debt was created, as to the likely future changes in the market rate of interest. Changes in the rate of interest which were not anticipated at the time the debt was created cannot be taken into account.