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HMRC internal manual

Capital Gains Manual

Other debts deemed to be securities: loan relationships of companies

TCGA92/S251 (7) and TCGA92/S251 (8) treats these debts as securities for TCGA purposes, where the disposal of the debt gives rise to a gain. You should note that this treatment applies only where there is a gain. The exemption in TCGA92/S251 (1) continues to apply, in appropriate cases, where there is a loss on disposal of these debts.