D6.115 Debentures Issued On A Reorganisation

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Commentary

Corporate tax

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:

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(a)�� a security³ (so that it is a chargeable asset, subject

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B3.325 General exclusions—first-year qualifying expenditure

I9.421 Situs of simple contract debts for IHT

I3.367 Fall in value relief—changes in interests in land

B2.306 General tests for distinguishing between capital and revenue expenditure

C2.1020 Employment-related securities options and capital gains

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