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HMRC internal manual

Business Income Manual

Transactions in land: Definitions: Disposal

S753 Income Tax Act 2007, S816 Corporation Tax Act 2010A disposal takes place not only when the land is sold but also when control over the land is disposed of.

For example, a disposal of a majority shareholding in a land owning company is a disposal of land for the purposes of the transactions in land rules.

The sale of a minority shareholding in a company is not normally a disposal for these purposes unless it can be shown that minority shareholders were acting in concert.