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A taxpayer has enquired about the taxation of the sale of company shares where the price consists of a fixed component and a variable component based on future conditions. The DGT indicates that the total price must be estimated and any difference regularised in subsequent tax years, or alternatively, the temporal imputation method may be used.
This ruling clarifies the tax treatment for deferred or contingent payments in share transfers, providing certainty on the use of estimation and subsequent regularisation to determine capital gains.
The tax team reviews your specific situation.
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