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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Qualifying corporate bonds: QCBs to QCBs

TCGA 1992 section 116 can only apply if there are qualifying corporate bonds (QCBs) on one side or the other of the transaction, but not on both sides. If for example as part of a takeover QCBs in the target company are exchanged for QCBs in the acquiring company section 116 will have no effect and the normal reorganisation rules in sections 127 - 131 continue to apply as appropriate.