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HMRC internal manual

Business Income Manual

Definitions: UK Land and property deriving its value from land

This legislation applies to UK land. UK land is described as any land situated in the United Kingdom.

 

The definition of ‘land’ is very wide and includes buildings and other structures, land covered with water (including seabed) and any estate interest, easement, servitude or right in or over land. This could include, but is not limited to, licenses and security interests over land.

The definition of ‘property deriving its value from land’ includes:

  • Any shareholding in a company deriving its value directly or indirectly from land,
  • Any partnership interest deriving its value directly or indirectly from land,
  • Any interest in settled property deriving its value directly or indirectly from land, and
  • Any option, consent or embargo affecting the disposition of land.

 

See Section 5A(3) CTA 2009, Section 356OR CTA 2010, Section 6B(3) ITTOIA 2005 and Section 517S ITA 2007.