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HMRC internal manual

Capital Gains Manual

Debts: satisfied by issuing shares or securities: conversion of securities

TCGA92/S132 may apply if

  • a debt that is a security
  • is acquired by the debtor company and
  • the company issues its own shares or other securities in satisfaction of the debt.

Guidance on TCGA92/S132 is at CG55000 onwards. When that section applies TCGA92/S127 operates so that the transaction is treated as involving no acquisition of the shares issued (see CG55000) so TCGA92/S251 (3) cannot apply.