Corporation Tax Act 2009 section 170

Meaning of "sale" and related expressions

Section 170 clarifies how references to a "sale" and related terms in the trading stock valuation rules (sections 164 to 167) should be interpreted when trading stock is transferred other than by a straightforward sale.

• For the purposes of the stock valuation rules in sections 164 to 167, a "sale" includes any transfer of trading stock made in exchange for valuable consideration, not just an outright sale
• This extended meaning of "sale" applies throughout sections 164 to 167, with the sole exception of section 167(5)
• Where a transfer is not technically a sale, the "amount realised on the sale" is taken to be the value of the consideration given for the transfer
• In such cases, the "buyer" means the person receiving the transfer, and the "seller" means the person making it