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HMRC internal manual

Capital Gains Manual

Debt on security: documentation

The existence of a formal document constituting or evidencing the debt is not an essential feature of the debt on a security. At page 194 in Ramsay Lord Fraser says `Further consideration has satisfied me that the existence of a document or certificate cannot be the distinguishing feature between the two classes of debt’. However, cases where debt on a security status is claimed for debts where no documentation exists need to be examined carefully to check whether or not the required features are present. Equally you should resist any suggestion that a debt MUST be a debt on a security if it is acknowledged by a document described as loan stock. This would be inconsistent with the approach taken in Ramsay, that the marketability test will be appropriate in deciding in ANY case whether a debt amounts to the debt on a security.