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Valuation of contract intangibles for tax and duty purposes
Published on 01 Oct 16 by "THE TAX SPECIALIST" JOURNAL ARTICLE
In “land rich” cases, the market value of land holdings is required to determine whether or not a liability to pay stamp duty arises or whether or not the market value of an entity’s assets that are taxable Australian real property (TARP) exceeds the sum of the market values of its assets that are non-TARP for capital gains tax purposes. The value of land assets /TARP assets relative to non-land assets/non-TARP assets is the focal point of “land rich” cases.
This article deals with the valuation of contract intangibles which is often a key category of identifiable intangible assets in “land rich” cases. Notwithstanding the discussion of the conceptual issues in the context of “land rich” cases, the conceptual framework established in this article can be applied to, or provide guidance for market value assessment in other tax contexts.