This example illustrates the operation of TCGA92/S138A if the deferred consideration is to be satisfied by an issue of Qualifying Corporate Bonds (QCBs). In the example the consideration to be received is immediate cash, immediate shares and an unascertainable deferred amount of debentures which are QCBs.

NOTE From 6 April 2008 only companies and other concerns within the charge to Corporation Tax may be able to claim indexation allowance, see CG17207.


In year 0 V Ltd acquires all the shares in T Ltd for £100,000.

In year 10 V Ltd sells all the shares in T Ltd at arm's length to P Ltd.

The consideration is

cash £200,000, and

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