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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Other tax rules on corporate finance: stock loans: taxation

Stock loan tax issues

Stock lending gives rise to a number of tax problems.

Loan relationships

The disposals and acquisitions would, in the case of an asset representing a loan relationship, constitute loan relationship related transactions. CTA09/S332 provides that where a company ceases to be party to a loan relationship but in accordance with GAAP continues to recognise amounts in respect of that relationship in determining its profit or loss, these amounts are brought into account in accordance with the loan relationships rules. See CFM33290.

Capital gains

The temporary transfers of securities between lender and borrower would, in the absence of specific legislation, constitute disposals for capital gains purposes. See CFM74140 and CFM74150.


See CFM74160 - CFM74180 for details of anti-avoidance measures.