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The expression applies if capital proceeds cannot be valued at all. Situations where capital proceeds cannot be valued are likely to be rare. Paragraph 116-30(2)(a) of the Income Tax Assessment Act 1997 (the capital proceeds market substitution rule) does not apply if valuing capital proceeds is merely difficult, costly or inconvenient.

As a matter of policy, it is inappropriate to apply the market value substitution rule to deem the market value of an asset to constitute the capital proceeds from a CGT event if it is at all possible to value the capital proceeds received. The substitution of market value should, therefore, be used in these circumstances only as a last resort.

The above analysis also applies to expenditure that cannot be valued in paragraph 112-20(1)(b) (the cost base market value substitution rule).