Chancery Division.

[The appeal against this decision is reported at [1998] BTC 297.]

Lloyd J.

Judgment delivered 20 December 1996.

Corporation tax – Chargeable gains – Assets sold for US dollars by instalments payable over nine years – Chargeable gain calculated in sterling at date of agreement – Depreciation of sterling over the nine years caused actual loss – Whether depreciation of sterling resulted in part of consideration becoming ‘irrecoverable’ – Capital Gains Tax Act 1979, s. 40(2) (Taxation of Chargeable Gains Act 1992, s. 48.

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