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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Qualifying corporate bonds: relevant: excluded indexed securities

It is possible that debts, which fall to be treated as excluded indexed securities from 6 April 1996, will have come to be held prior to this date as a result of a company reorganisation. Where, in these cases, the debts were at that time treated as QCBs and TCGA92/S116 (10) applied, see CG53820+, they will continue to be treated as QCBs for this purpose. Any gain or loss under TCGA92/S116 (10) will crystallise in the usual way on a disposal of the excluded indexed security.