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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/S251 (6)

The rules in CG55024 and CG55025 establish whether there has been a conversion of securities in these cases. In conjunction with these changes, TCGA92/S251 (6) was extended so that any debenture which results from a conversion of securities within TCGA92/S132, or is issued as a result of rights attaching to such a debenture, is deemed to be a security for the purposes of that Section. So, once it is established that the transaction is - following the new rules - a conversion, this then ensures that the debt emerging from the conversion will be a security, for the purposes of TCGA92/S251.