Where an agreement for the sale of shares in or debentures of a company provides for deferred unascertainable consideration which is to be satisfied wholly or partly by shares or debentures issued to the vendor, then TCGA92/S138A may result in TCGA92/S135 operating so that the no disposal/same asset treatment of TCGA92/S127 applies with the necessary adaptations. The guidance on TCGA92/S135 is at CG52500+ and on TCGA92/S138A is at CG58000+.
Proceeds lent back to purchaser
If the proceeds of the sale are lent by the vendor to the purchaser there are two separate transactions:
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