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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Conversion of securities: change in status of debt S88 FA 1997

The FA 1997 rules were enacted so that there could be no doubt as to the tax position in relation to the cases described above. There are however several possible technical defences against the sort of argument outlined in CG55021, which may apply in cases where the disposals took place before the new rules came into force. The approaches available will depend on the precise facts and circumstances. Capital Gains Technical Group will be happy to advise in such cases.