CG53435 - Debt on security: loan stock or similar security
In Ramsay Lord Wilberforce did not regard it as necessary to decide whether the loan L2 was, in fact, within the meaning of loan stock'. He observed that TCGA92/S132 (3)(b)
includes within security' any
similar security’ to loan stock: in my opinion these words cover the facts. This was a contractual loan, with a structure of permanence such as fitted it to be dealt in …’ (page 190). Lord Fraser took a similarly broad approach in his judgment (page 194).