If, on a proper analysis of the consideration, part of that consideration is ascertainable but not payable until a future date, no discount is permitted for the risk of non-receipt, for the opportunity cost of the funds (say, lost interest) or for the reduced purchasing power which those funds might have at the time of receipt (TCGA 1992, s. 48).


Linda sells an asset for £35,000. The consideration is to be paid as to £20,000 immediately, £10,000 in six months time and £5,000 on the anniversary of the date of disposal.

The disposal consideration to be taken into account is the full £35,000.

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