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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Qualifying corporate bonds: identification: general

The share identification rules in TCGA 1992 refer at particular sections to relevant securities. The definition of relevant securities is provided by TCGA 1992 section 108(1) and includes qualifying corporate bonds (QCBs).

Section 104(3) provides that sections 104, 105, 107 & 110 do not apply to relevant securities. Therefore these sections do not apply to QCBs.

Section 107 provides general rules on the identification of securities for corporation tax so a disposal of QCBs by a company is not subject to the share identification rules.

Specific rules do exist for non corporate holders of QCBs and they are contained within section 106A. Appendix 10 of the CG guidance manual provides fuller details on the operation of section 106A. Note: There are no analogous rules similar to section 106A for corporate holders of QCBs.

See CG50500+ for a fuller explanation of the rules relating to share identification.