Taxation of Chargeable Gains Act 1992 section 48

Consideration due after time of disposal

Section 48 deals with how disposal consideration that is deferred, contingent, or potentially irrecoverable should be brought into account when computing a chargeable gain.

• The full consideration for a disposal must be included in the gain computation at face value, with no discount for deferred payment, risk of non-recovery, or contingency
• If any part of the consideration later proves irrecoverable, the taxpayer can make a claim for an adjustment (by way of tax discharge, repayment, or otherwise)
• Where the consideration includes rights under a creditor relationship that a company acquires as a result of the disposal, the normal rule does not apply — instead, the fair value of that creditor relationship is brought into account
• The terms "creditor relationship" and "fair value" take their meanings from Part 5 of the Corporation Tax Act 2009