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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Qualifying corporate bonds: FA96: loan relationships

This guidance describes the capital gains aspects of the regime for Loan Relationships for companies from 1 April 1996 until the first accounting period to start on or after 1 October 2002. For periods beginning on or after 1 October 2002 see CG54100+

The following categories of loan relationship are not treated as QCBs for the purposes of Corporation Tax

  • loan relationships which are convertible into, or give rights to acquire, shares, see CG54025
  • loan relationships which are linked to the value of chargeable assets, see CG54030 and
  • certain loan relationships held in exempt circumstances, see CG54035.