Contents
Chapter 1 – Introduction
Chapter 2 – Issues with mixed supplies and allocation of purchase price
- Generalising from the example
- The special case of depreciable property
- Inconsistent allocations
- Concluding remarks on the significance of allocation for tax
Chapter 3 – Current law
Chapter 4 – Issues arising in practice
- Inconsistent valuations
- Consistent valuations not within a market range
- No explicit market value requirement for a purchaser of depreciable property
- Place of anti-avoidance rules
Chapter 5 – The proposed solutions
- Policy framework
- Outline of proposals
- Agreed allocation
- No agreed allocation
- Contest rights
- De minimis
Chapter 6 – Issues to consider
- Effect of the proposal on commercial behaviour
- Sales for a bargain price
- Auctions and tenders
- Sales involving dealers or other revenue account holders
- Degree of consistency
- Denial of a deduction for purchasers who disregard the law