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HMRC internal manual

Capital Gains Manual

Qualifying corporate bonds: general background

This section of the manual concentrates on the application of the TCGA to Qualifying Corporate Bonds (QCBs) that do not come within other parts of the Taxes Acts.

Note that TCGA 1992 section 117(A1) specifically provides that any asset that represents a loan relationship of a company is a QCB, see CG53704 below.

The guidance on QCBs begins with the legislation that was in place at 2002 and explains changes made since that date. If you need to consider the guidance on legislation before 2002 then this is available from commercial tax information packages or directly from Capital Gains Technical Group.

A number of cases have been heard by the courts involving schemes that were designed to exploit the interaction of sections of the statute within TCGA 1992 Part IV Chapters 1 & II. Guidance on these can be found at CG 53729.