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HMRC internal manual

Capital Gains Manual

Land: disposals: unascertainable deferred consideration: part chargeable as capital gain

Where transactions in land provisions apply, the market value of the land at the date of contract will usually exceed the initial cash payment due under the contract. The sum of that excess (if any) and the initial cash payment will be the consideration taken into account in computing the gain arising. If the taxpayer is not prepared to accept that the gain should be calculated in this way, the case should be referred to Capital Gains Technical Group.

In a case such as this, it will not be necessary to refer the valuation of the right to receive the deferred consideration to the Valuation Office Agency under CG72880-CG72881.