Deferred consideration: unascertainable: assessable amount and valuation issues
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 CG72880. For other assets, send the request for a valuation with a full copy of the relevant sale agreement to:
- Shares and Assets Valuation, Fitz Roy House, Nottingham
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.