Income Tax Act 2007 section 436

Consideration

Section 436 explains how the consideration received for a disposal of shares, securities or real property to charity is to be valued when calculating the relievable amount under section 434.

• The full face value of the consideration must be used in the calculation, with no discount for any delay in receiving payment.
• Initially, no allowance is made for the risk that any part of the consideration may prove irrecoverable.
• Initially, no reduction is made for any part of the consideration that depends on a contingent event.
• If any part of the consideration later proves irrecoverable, a claim can be made and an appropriate adjustment will be given by way of tax discharge, repayment or otherwise.