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Contents

Official guidance
Capital Gains Manual

CG14480P · Capital Gains manual: introduction and computation: computation: consideration for disposal

  • CG14480 · Consideration for disposal: introduction
  • CG14500 · Consideration for disposal: meaning of consideration
  • CG14504 · Consideration for disposal: meaning of: right to series of payments
  • CG14507 · Consideration for disposal: meaning of consideration: rent charges
  • CG14530 · Consideration for disposal: market value rule
  • CG14540 · Consideration for disposal: market value rule: not at arm's length
  • CG14541 · Consideration for disposal: market value rule: at arm's length
  • CG14542 · Consideration for disposal: market value rule: subjective intention test
  • CG14543 · Consideration for disposal: market value rule: apply to each transaction
  • CG14544 · Consideration for disposal: market value: gratuitous benefit conferred
  • CG14545 · Consideration for disposal: market value rule: objective indicators
  • CG14546 · Consideration for disposal: market value rule: subjective intention test
  • CG14547 · Consideration for disposal: market value rule: control
  • CG14548 · Consideration for disposal: market value rule: share subscriptions
  • CG14549 · Consideration for disposal: market value rule: company reorganisations
  • CG14550 · Market value rule: acquisition no disposal: disposal no acquisition
  • CG14560 · Transactions between connected persons
  • CG14561 · Transactions between connected persons: clogged losses
  • CG14562 · Transactions between connected persons: gifts into certain settlements
  • CG14565 · Transactions between connected persons: subject to right/restriction
  • CG14570 · Transactions between connected persons: limitation to operation of S18
  • CG14580 · Connected persons
  • CG14584 · Connected persons: relatives
  • CG14590 · Connected persons: trustees
  • CG14596 · Connected persons: trustees: pension funds
  • CG14610 · Connected persons: partners
  • CG14620 · Connected persons: companies: and other companies
  • CG14622 · Connected persons: companies: 2 or more persons acting together to control
  • CG14623 · Connected persons: directors of a company
  • CG14627 · Connected persons: share disposal following asset transfer from
  • CG14650 · Assets disposed of: series of transactions: introduction
  • CG14653 · Assets disposed of: series of transactions: statutory provisions
  • CG14657 · Assets disposed of: series of transactions: portion of aggregate MV
  • CG14680 · Assets disposed of: assets acquired after series of transactions started
  • CG14700 · Assets disposed of: series of transactions: groups of companies
  • CG14710 · Assets disposed of: series of transactions: spouses or civil partners
  • CG14730 · Assets disposed of: series of transactions: assessments
  • CG14740 · Assets disposed of: series of transactions: approach
  • CG14770 · Assets disposed of: series of transactions: xfers at undervalue
  • CG14771 · Introduction and computation: computation: consideration for disposal: apportionment when assets disposed of in a series of transactions
  • CG14773 · Assets disposed of: series of transactions: apportionment
  • CG14780 · Assets disposed of: Series of transactions: liaison between districts
  • CG14781 · Assets disposed of: series of transactions: just and reasonable
  • CG14782 · Assets disposed of: series of transactions: apportionment techniques
  • CG14783 · Assets disposed of: series of transactions: market value
  • CG14787 · Assets disposed of: series of transactions: problems
  • CG14790 · Assets disposed of: series of transactions: capital allowances
  • CG14795 · Assets disposed of: series of transactions: composite sale/separate contracts
  • CG14800 · Contingent liabilities: what is a contingent liability?
  • CG14804 · Contingent liabilities: TCGA92 S49
  • CG14805 · Contingent liabilities: the effect of TCGA92 S49
  • CG14807 · Contingent liabilities: the effect of TCGA92 S49: negative consideration
  • CG14809 · Contingent liabilities: the effect of TCGA92 S49: incidental costs
  • CG14815 · Contingent liabilities: warranties and representations
  • CG14818 · Contingent liabilities: warranties/representations: share exchanges
  • CG14821 · Contingent liabilities: warranties/representations: qualifying corporate bonds
  • CG14825 · Contingent liabilities: indemnities
  1. Capital Gains manual: introduction and computation: computation: consideration for disposal: contents
  2. Assets disposed of: series of transactions: apportionment techniques

CG14782 | Assets disposed of: series of transactions: apportionment techniques

From HM Revenue & Customs · Capital Gains Manual

There are various techniques you can use in making an apportionment or re-apportionment. The method you use in any given case will depend on the facts of the case and the guidance given here is not meant to be exhaustive. In many cases, you will be able to obtain expert assistance from one of the specialist valuation offices. Certain cases must be submitted to those offices, please refer to the appropriate guidance.

In our view, any apportionment has to be ‘just and reasonable’ by reference to the facts of the case. In trying to arrive at such an apportionment, therefore, your first source of information will be the documentation. Is there anything in it which suggests that although the parties settled on a global figure, they based that on separate figures for the various assets? If so, those separate figures may be a good starting point for an apportionment.

If you are dealing with a disposal of business assets, is there anything in the balance sheet to help you? For example, if the assets sold include fixtures and fittings, are these relatively new or are they the originals which are now worn out or obsolete?

If you are dealing with a company, then the Directors’ Report might help. Does it include any details of property revaluation, for example?

The background to the actual transaction may help you. Was it, for example, a forced sale by creditors?

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