The provisions described in this article do not apply to persons chargeable to corporation tax1.
As set out in C2.107, where the consideration for the disposal of an asset includes deferred unascertainable consideration, the initial chargeable gain includes as consideration the value at that time of the right to receive future payments. Further gains and/or losses arise as and when the deferred right is realised. If the total amount realised is less than the value included in the original capital gain, a capital loss will arise on the disposal of the right to the future payments. The loss on the disposal of the right to receive payment can be carried back against the gain on the original disposal, provided an election is made2.
Election for treatment of loss
A person ('the taxpayer') is entitled to elect for an allowable loss ('the relevant loss'), which would otherwise accrue to them in one tax year ('the year of the loss'), to be treated as accruing to them in an earlier tax year
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