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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Other debts deemed to be securities: excluded indexed securities

FA96/SCH12/PARA13

FA96 also amended the taxation treatment of discounted debts held by individuals and other non-corporates. In general, profits or losses on these debts are charged or allowed as income. For further detail see CG54200+.

Discounted debts which are linked to the value of chargeable assets - referred to as excluded indexed securities - are again kept within the capital gains regime because their value will reflect the value of the shares or other chargeable assets to which they are linked. TCGA92/S251 (7) and TCGA92/S251 (8) apply here also, see CG53445.