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HMRC internal manual

Capital Gains Manual

Computation: IT: transactions in land

ICTA88/S776 and ITA2007/S752-772 and CTA2010/S815-833

Where ICTA88/S776 or ITA2007/S752-772 or CTA2010/S815-833applies, see BIM60300 onwards, the gain or part of the gain realised on a transaction in land may be charged as income on the person who realised the gain. The gain or part of the gain so charged as income is not also to be charged to Capital Gains Tax.

For further details of the interaction with capital gains tax see CG72852 - CG72857.

ICTA88/S777 (12) and ITA2007/S759(4) and CTA2010/S821(5)

Under ICTA88/S776 (8) or ITA2007/S759(4) or CTA2010/S821(5) the gain may be charged on a person other than the person who realised the gain, see BIM60335. Provided that the tax charged has been paid, you should treat the person who realised the gain as having been charged to that tax and should not charge them to Capital Gains Tax.