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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Disposal of assets: general

TCGA92/S1 (1)

Chargeable gains (or allowable losses) accrue on the disposal of assets. The word ‘disposal’ is not expressly defined in the TCGA92 and therefore must be given its natural meaning.

  • Sales, gifts and exchanges are examples of natural disposals.
  • There are specific occasions and occurrences which are defined by the Act to be disposals, see CG12702-CG12705.
  • A series of transactions may be so closely linked that, as a matter of legal construction, they should be regarded as constituting a single disposal.

In general, there is a chargeable occasion whenever a capital sum is received, where the receipt can be related to

  • the ownership of an asset, or
  • to an interest in or right in or over an asset,

except where the transaction is specifically exempted. ‘Ownership’ means beneficial ownership, see CG34300+.