Commentary

C3.712 Conditions for relief

Capital gains tax
Capital gains tax | Commentary

C3.712 Conditions for relief

Capital gains tax | Commentary

C3.712 Conditions for relief

The rules described in this article do not apply for capital gains tax purposes in relation to loans made after 16 March 1998, and no longer apply for corporation tax purposes since the introduction of the loan relationship regime (see C3.711).

For the purposes of this relief a 'qualifying loan' was defined as a debt on a security1 which would otherwise have been a qualifying loan for the purposes of TCGA 1992, s 253 (see C3.703) and which was a qualifying corporate bond but which was not a deeply discounted security for the purposes of ITTOIA 2005, ss 427–460 (Pt 4, Ch 8)2. The borrower therefore had

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