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HMRC internal manual

Capital Gains Manual

Securities: debts: general points: bundle of rights

In the case of Cleveleys Investment Trust Co v CIR, 47TC300, there had been an arrangement between that company and another (Falkirk) that

  • a loan would be made by Cleveleys to Falkirk, and
  • on a capital reconstruction of Falkirk the loan would be discharged in return for an allotment of 51 per cent of the share capital in Falkirk to Cleveleys.

Falkirk however went into liquidation before any capital reconstruction took place. Cleveleys wrote off the debt, and sought a capital loss in respect of it.