CGT Determination Number 9

TD 9

Capital Gains: How do you apportion consideration received on the disposal of a composite asset?

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FOI status:

may be releasedFOI number: I 1018979

1. Section 160P outlines a number of situations in which the consideration for the disposal of a composite asset (deemed to comprise separate assets) requires apportionment.

2. There is no statutory formula to be used by taxpayers in determining the consideration for the disposal of an asset deemed by section 160P to be a separate asset.

3. It is not mandatory that taxpayers obtain an independent valuation for the purposes of apportioning the consideration received on disposal. Each taxpayer should take whatever steps are appropriate to determine the valuation of the particular asset. Taxpayers who choose to do their own apportionments will, of course, need to be in a position to justify the estimates that they make.

Note:
The ATO may challenge valuations where appropriate.

Commissioner of Taxation
10 September 1991

References

ATO references:
NO N.O. 86/7539-2

ISSN 1037 - 1419

Subject References:
Disposal of composite asset;
Apportionment of consideration

Legislative References:
160P

TD 9 history
  Date: Version: Change:
You are here 10 September 1991 Original ruling  
  29 November 2006 Original ruling + note Repeal provision note