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HMRC internal manual

Oil Taxation Manual

Capital gains: consideration other than cash: introduction

Valuing non-cash elements of the consideration given for farm-outs of licence interests is complex and there are no rigid guidelines. Appropriate weight must be given to the actual and particular facts. These include the precise arrangements and the rights and obligations under various agreements (including the joint operating agreement) which will need careful scrutiny.

TCGA92\S17 provides that if an asset is disposed wholly or partly for a consideration which cannot be valued, the disposal is deemed to be for a consideration equal to the market value of the asset.