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:

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.

Commissioner of Taxation
10 September 1991

References

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

Subject References:
Disposal of composite asset;
Apportionment of consideration

Legislative References:
160P