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HMRC internal manual

Capital Gains Manual

Deferred consideration: not instalments of capital sum: land development

ITA2007/S752 (CTA2010/S815)

You need to consider whether the transaction comes within the scope of ITA2007/S752 for income tax (or CTA2010/S815 for corporation tax) if the asset sold is

  • land,


  • an interest in land,


  • property deriving its value from land, for example shares in a property owning company.

There are detailed instructions in CG72800+.