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HMRC internal manual

Capital Gains Manual

Chargeable assets: general

TCGA92/S1 (1) & TCGA92/S21 (1)

Chargeable gains accrue on the disposal of assets. Assets include all forms of property wherever they are situated including

  • shares and securities
  • interests in land
  • options, debts and rights over property
  • any currency other than sterling (the £ sterling being simply the unit of measurement of value)
  • any property which was created by the person disposing of it such as business or professional goodwill, copyright or a lease (by the granting of it).

The definition of an asset in TCGA92/S21 (1)(a) includes incorporeal property generally. In this context, incorporeal property includes contractual rights, whether or not those rights are capable of being transferred or assigned, and whether or not they have a market value (O`Brien v Benson’s Hosiery (Holdings) Ltd, 53TC241), see CG12020.