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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Debts: satisfied by issuing shares or securities

One of the most common situations where TCGA92/S251 (3) applies is when a loan is converted into shares. A person who has made a loan to a company may take shares issued by the company and meet the subscription price by reducing the amount of the loan.

However, TCGA92/S251 (3) does not override the ordinary rules of

  • TCGA92/S126 to TCGA92/S128, which apply to share reorganisations (see CG53516A), or
  • TCGA92/S132, which applies to the conversion of securities (see CG53517), or
  • TCGA92/S135, which applies to share exchanges (see CG53518).