[CG55019] Conversion of securities: change in status of debt S88 FA 1997
The purpose of these rules was to provide a clear legislative counter to schemes under which it was for example claimed that
•an alteration in the terms of a debt, or a change in the practical effect of the debt's terms during its life, can turn a debt which is a chargeable asset into a capital gains exempt qualifying corporate bond (QCB);
•there is no disposal of the debt when its tax status changes;
•any gain which would have been chargeable on a disposal of the debt at the time of the change is not taxable when the debt is later disposed of.