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.

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