½Û×ÓÊÓƵ

Where more than one asset is disposed of under a single transaction, it may be necessary to allocate the consideration to each asset separately, where this is not done by the contract. Any apportionment of consideration is to be made on a just and reasonable basis. Under the self-assessment regime, the taxpayer initially apportions the consideration¹.

HMRC take the view that it is permitted to reallocate the consideration on a just and reasonable basis where there is no apportionment provided by the parties or where the apportionment provided is unreasonable on the facts of the case².

Other instances where consideration may need to be apportioned include:

1. Ìý

   •ÌýÌýÌýÌý all of part of a business has been disposed of and a separate figure for goodwill is needed, see C3.1501

2. Ìý

   •ÌýÌýÌýÌý compensation is received on the compulsory acquisition of land, see C2.1115–C2.1118

3. Ìý

   •ÌýÌýÌýÌý the asset disposed of qualified for capital