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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Securities: debts: general points: bundle of rights

The Court of Session decided, by a majority, that the arrangements gave rise to a `bundle of rights’, which included the rights to shares in a reorganisation of Falkirk’s share capital. The asset which Cleveleys held was not simply a debt, but incorporeal property, which fell within the generality of chargeable assets (now TCGA92/S21 (1)(a) ). It was not possible to separate the loan element from the other elements, and the general restriction on debts (now TCGA92/S251 (1) ) had no application. The whole of the loss suffered by Cleveleys was, therefore, allowable.