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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Deferred consideration: shares and securities: restriction where liability final

FA97/S89 (4)

Where an earn-out right was acquired before 26 November 1996 the taxpayer cannot elect if their liability to Corporation Tax or Capital Gains Tax for the chargeable period when they obtained the earn-out right has been finally determined.