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HMRC internal manual

Capital Gains Manual

Assets disposed of: Series of transactions: liaison between districts

As we need to arrive at the same result for buyer and seller, it is important that you liaise with your counterpart. We would expect the District dealing with the seller to take the lead in this and to seek to agree any apportionment with the seller or their agents. This applies even where the buyer’s District is dealing with a claim to Capital Allowances, see CG14790 and CA302.

If you are unable to reach agreement with the seller on any apportionment, then the matter will need to be considered by the First-tier Tribunal or other appeal body, such as the Lands Tribunal. You should refer to the parts of the manual dealing with the asset(s) concerned for guidance on appeal procedures. For example:

  • see CG68330 for cases involving goodwill
  • see CG74150+ for cases involving land and buildings
  • see CG77016+ for cases involving chattels.

If you have to take an apportionment to an appeal, then you should always link the other party to the appeal by using SI1967/149, see CG16401+.