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HMRC internal manual

Capital Gains Manual

Deferred consideration: shares and securities: rights acquired pre-26/4/88

Paragraph 4 of ESC/D27 dealt with cases where

  • the right to unascertainable consideration was acquired before 26 April 1988, and
  • under the agreement the right could be satisfied in cash or some other alternative to shares or debentures, and
  • there was a maximum amount to the consideration.

The conditions for TCGA92/S135 to apply also have to be met as a result of the application of this part of the concession.