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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Assets disposed of: series of transactions: apportionment techniques

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?