This example illustrates the effect of TCGA92/S138A if the customer receives an immediate issue of debentures, which are Qualifying Corporate Bonds (QCBs), and an unascertainable deferred amount of shares and debentures, which are also QCBs.

NOTE From 6 April 2008 only companies and other concerns within the charge to Corporation Tax may be able to claim indexation allowance, see CG17207.


In year 0 V Ltd acquires all the shares in T Ltd for £100,000.

In year 10 V Ltd sells the shares in T Ltd at arm's length to P Ltd.

The consideration is

debentures of P Ltd to the value of £300,000

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