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HMRC internal manual

Capital Gains Manual

Securities: debts: general points: payments under guarantee


Although there can be no allowance for any resulting loss on normal capital gains principles, payments under guarantees may give rise to allowable losses under the specific provisions of TCGA92/S253, see CG65900+. Where relief has been given under these sections, any sums subsequently received by the guarantor in respect of the debt will be subject to a recovery charge, so that the relief is restricted to the net amount paid out by the guarantor.