Capital Gains & Other Taxes Manual - Appendix 23 : Extract from reply by the Chief Secretary to the Treasury in Standing Committee E debate on the Finance Bill 1972 - : 22 June 1972 Column 1358

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APPENDIX 23 : Extract from reply by the Chief Secretary to the Treasury in Standing Committee E debate on the Finance Bill 1972 - : 22 June 1972 Column 1358

“In considering whether undue hardship would arise, the Revenue would look primarily to the question whether the vendor or disposer could reasonably be expected to pay the tax on the full amount immediately, in the light of the resources made available by the particular transaction involved. Regard would not normally be paid to the other resources of the taxpayer if it could be shown that the instalment arrangement was in the circumstances, and apart from any tax considerations, a normal commercial arrangement and reflected a genuine deferment of the enjoyment of the consideration. The Revenue practice would, of course, be kept under review, in the light of its effect on actual cases arising”.

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