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HMRC internal manual

Capital Gains Manual

Qualifying corporate bonds: FA2002: loan relationships

This guidance describes the capital gains aspects of the regime for Loan Relationships for companies for accounting periods ending on or after 26 July 2001 unless the company ceased to be a party to the relationship before that date. For periods ending before 26 July 2001, and where the companies ceased to be a party to a relationship before that date, see CG54000+.

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 CG54125, and
  • loan relationships which are linked to the value of specific kinds of chargeable assets, see CG54130.