[48A Unascertainable consideration]

[48A  Unascertainable consideration]

[(1)     This section applies where—

[(a)     a person (“P”) has made a disposal (“the original disposal”) on which a relevant non-resident gain or relevant non-resident loss accrued,]

(b)     P acquired a right as the whole or part of the consideration for that disposal,

(c)     on P's acquisition of the right, there was no corresponding disposal of it, and

(d)     the right is a right to unascertainable consideration (see subsections (4) to (6)).

(2)     If P subsequently receives consideration (“the ascertained consideration”) representing the whole or part of the consideration referred to in subsection (1)(d) and [P is not UK resident for the tax year in which the ascertained consideration is received (as determined for the purposes of Chapter 1 of Part 1)—]

(a)     the ascertained consideration is treated as not accruing on the disposal of the right,

(b)     the costs of P's acquisition of the right (or, in the case of a part disposal of the right, those costs so far as referable to the part disposed of) are taken to be nil, and

(c)     the following steps are taken.

Step 1
Any amount by which the

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