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HMRC internal manual

Capital Gains Manual

Qualifying corporate bonds: securities issued in separate tranches

FA96/SCH13/PARA10FA96/SCH13/PARA10 covers cases where securities are issued in separate tranches under a prospectus. In these circumstances, it is possible that the original issue under the prospectus does not meet the test for deepness`, see CG54210, but - as a result of subsequent movements in the market - some or all of the later issues would.

In these cases, NONE of the securities issued under the prospectus are treated as relevant discounted securities, until the aggregate nominal value of the tranches which would qualify exceeds the aggregate nominal value of the tranches which do not. Once this point is reached, then in relation to any later event all the securities issued under the prospectus are treated as relevant discounted securities (and are treated as having been acquired as such). See the example at IM1544g.