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HMRC internal manual

Capital Gains Manual

Debt on security: loan stock or similar security

In Ramsay Lord Wilberforce did not regard it as necessary to decide whether the loan L2 was, in fact, within the meaning of `loan stock’. He observed that TCGA92/S132 (3)(b) `includes within `security’ any `similar security’ to loan stock: in my opinion these words cover the facts. This was a contractual loan, with a structure of permanence such as fitted it to be dealt in …’ (page 190). Lord Fraser took a similarly broad approach in his judgment (page 194).