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

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 the shares in T Ltd at arm's length to P Ltd.

The consideration is

cash £100,000, and

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