Commentary

C2.106 Deferred consideration

Capital gains tax
Capital gains tax | Commentary

C2.106 Deferred consideration

Capital gains tax | Commentary

C2.106 Deferred consideration

The amount of the actual consideration received for the disposal is normally ascertained at the time of disposal and brought into account:

  1.  

    (a)     without any discount for postponement of the right to receive any part of it, and

  2.  

    (b)     in the first instance, without regard to a risk that any part of the consideration is irrecoverable, or to the fact that the right to receive any part of the consideration is contingent1

The reference in (a) to discount does not apply to a loan relationship. Instead the chargeable gain arising from rights under a creditor loan relationship is

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