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HMRC internal manual

Capital Gains Manual

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

TCGA92/S132 (4)(a), TCGA92/S132 (4)(b), TCGA92/S132 (5)

The two basic categories mentioned in CG55024 are extended to cater for cases where Section 251(6) TCGA 1992, see CG53442, would apply. Thus the first bullet above covers also cases where

  • the first debt is deemed to be a security, by TCGA92/S251 (6); and where
  • the second debt is one which, if TCGA92/S251 (6) applied, would be a QCB.

In the same way, the second bullet in CG55024 covers cases where

  • the first debt is a QCB because TCGA92/S251 (6) and TCGA92/S117 (6A) have applied; and includes cases where
  • the second debt is one which is not a security, and would not be a QCB even if TCGA92/S251 (6) applied.