Revenue Note for Guidance
This section provides that the computation of a chargeable gain for both capital gains tax and corporation tax purposes is to be made without taking into account any discount for the postponement of payment, and without regard to any risk that any part of the payment may prove to be irrecoverable or to the right to receive any part of the payment being conditional. If, however, it is later shown to the satisfaction of the inspector that any part of the consideration has become irrecoverable, any necessary adjustment of the charge to tax is to be made. The adjustment may be made by repayment or discharge of tax or otherwise. The general time limit for making a claim for a repayment of tax set out in section 865 shall not prevent the Revenue Commissioners from making a repayment of tax on foot of an adjustment.
Relevant Date: Finance Act 2019