Commentary

D6.115 Debentures issued on a reorganisation

Corporate tax
Corporate tax | Commentary

D6.115 Debentures issued on a reorganisation

Corporate tax | Commentary

D6.115 Debentures issued on a reorganisation

For a company, debentures are automatically treated as qualifying corporate bonds (QCB) as they represent a loan relationship of the company (see Division D1.7)1.

For all other situations, where a debenture is issued after 15 March 1993 to which the reorganisation rules (D6.102) apply2 it is deemed to be both:

  1.  

    (a)     a security3 (so that it is a chargeable asset, subject to (b) below), and

  2.  

    (b)     a 'temporary' corporate bond, for the purpose of the definition of QCB4. (Provided it would be a corporate bond if it were a security as defined in TCGA 1992,

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