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HMRC internal manual

Business Income Manual

Transactions in land: Common situations: 'Slice of the action' contracts: Identification

The vendor, and their advisors, may be unaware that the transactions in land anti-avoidance rules are applicable to ‘slice of the action’ contracts (see BIM60350).

Cases are frequently identified by HMRC Officers when the staged contingent payments are received, following development, and capital gains ‘part disposal’ computations are submitted.

Any case where an Officer considers that the anti-avoidance provisions apply must be submitted to CTISA (Technical) before the matter is raised with the taxpayer or agent.