CG14950 | Deferred consideration: unascertainable: assessable amount and valuation issues

From HM Revenue & Customs · Capital Gains Manual

The value of the right to receive the future payments is included in the consideration for the disposal. This principle was established in two tax cases, Marson v Marriage (54TC59) and Marren v Ingles (54TC76) see CG14990.

There is a separate chargeable occasion when each instalment of future payment is received.

To consider any computation of a gain provided you will need to know:

  • what is to be valued, and

  • what valuation the taxpayer wishes to put forward.

To review what has been returned you may need to obtain a valuation.

Where the original asset disposed of was land, see CG72850. For other assets, send the request for a valuation with a full copy of the relevant sale agreement to:

  • Shares and Assets Valuation, Nottingham use

Remember that if you are only risk-assessing a computation you may only need an informal valuation. Any request for a valuation should give -

  • details of the original asset disposed of

  • what is to be valued

  • the date at which the valuation is to be made

  • the name and address of the taxpayer

  • the name and address of any agent

  • details of any valuation supplied by the taxpayer.

  • details of whether an informal or agreed valuation is required.