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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
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Debts which are debts on a security: losses: disposals: connected persons

TCGA92/S251 (4)

CG53481 explains the anti-avoidance provisions of TCGA92/S251 (4) which apply to losses arising on disposals of debts by persons connected with the original lender. Although the word `debt’ is not qualified, in the Revenue’s view TCGA92/S251 (4) does not apply to debts on a security.