Section 45

(1) For the purposes of computing chargeable gains, unless the context
market value otherwise requires, market value, in relation to any asset, means the price
which the asset might reasonably be expected to fetch on a sale conducted at
arm's length, or in the open market.
(2) In estimating the market value of any asset in the case of a disposal,
no reduction shall be taken into account for cash or bulk discount.
(3) In determining the acquisition cost of any asset, where the actual
consideration paid by the acquirer is less than the market value, the assets
shall be deemed to have been acquired for the amount actually paid.
Location of 46. For the purposes of Chapter Two of this Act –
assets
(a) the situation of rights or interests, other than by way of security, in or
over immovable property is that of the immovable property;
(b) the situation of rights or interests, other than by way of security, in or
over tangible movable property is that of the tangible movable property;
(c) a debt, secured or unsecured, is situated in Nigeria where the creditor
is resident in Nigeria, or has a permanent establishment in Nigeria to which
the debt relates;
(d) shares or securities issued by any governmental, municipal or local
authority, or by a body created by such an authority, are situated in the
country of that authority or place where the authority is situated;
(e) subject to paragraph (d), registered shares or securities are situated
where they are registered and, if registered in more than one register, where
the principal register is situated;
(f) notwithstanding paragraph (e), shares or comparable interests in any
foreign entity are deemed to be located in Nigeria, if, at any time during the