1
(1)
The chargeable consideration for a transaction is, except as otherwise expressly provided, any consideration in money or money’s worth given for the subject-matter of the transaction, directly or indirectly, by the purchaser or a person connected with him.
(2) Section 1122 of the Corporation Tax Act 2010 (connected persons) applies for the purposes of sub-paragraph (1).
Cases considering Schedule 4, paragraph 1 7
[2018] UKSC 30 · 13 June 2018Defines
Supplied the general definition of chargeable consideration, read with the special rules for contingent consideration and the section 75A calculation. (see paras [60]-[64])
[2024] EWCA Civ 92 · 8 February 2024Interprets
Schedule 4 paragraph 1 was interpreted to include consideration in money or money’s worth given indirectly by the purchaser or a connected person. The phrase was not confined to payment mechanics; the pre-ordained scheme had to be assessed in the round. (see paras [23]; [52]-[56])
[2013] EWCA Civ 907 · 25 July 2013
Absent an express alternative rule, chargeable consideration is the money or money's worth given directly or indirectly for the transaction. This rule determined the consideration for the partnership's acquisition (see paras [7]; [37]).
What each judgment says about Schedule 4, paragraph 1 is in the case-law panel in the full Act.