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HMRC internal manual

Capital Allowances Manual

MEA: Group transfers: interest in land

Where the mineral asset to which CAA01/S412 applies is an interest in land, and a restriction of qualifying expenditure is needed under CAA01/S404 (exclusion of undeveloped market value):

  • references in Section 404 to the time of acquisition are treated as references to the time of acquisition by the transferor and not the transferee,



  • by the earliest transferor if there is a sequence of intra-group transfers.