Preamble
No. The mere fact that the liquidator has declared that the securities (other than shares) have no value is not sufficient to be a disposal for CGT purposes. A capital loss, therefore, does not arise.
A disposal would occur where, for instance, an unconditional sale of a security to another person takes place (subsection 160M(1)) or where all rights under that security are legally and irrevocably surrendered, released or abandoned, e.g. by the taxpayer executing a deed of release in favour of the company (paragraph 160M(3)(b)). Note: Section 160WA does not apply to securities other than shares. Broadly, section 160WA enables a shareholder in a company in liquidation to elect to treat shares as disposed of before dissolution of the company (see TD 92/102, TD 93/179). The section applies only to shares held in companies in liquidation which have been declared to be valueless by the liquidator.