While most debts are exempt from tax on chargeable gains in the hands of the original creditor, there is an exception ‘in the case of the debt on a security (as defined in TCGA 1992, s. 132)’ (see ¶510-900). There are also various other effects of a debt being one ‘on a security’ as so defined.

The expression ‘the debt on a security’ is an unfamiliar one (see Lord Fraser in WT Ramsay v IR Commrs [1982] AC 300 at p. 333). It is likely that the legislation was so phrased in order to include any ‘security’ which represents a debt.

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