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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Assets held on 6/4/65: relevant date

TCGA92/SCH2/PARA16 (4)Where expenditure is reflected in an actual addition to, or work on, an asset (including work in progress), the item of expenditure should be regarded as having been first reflected in the state or nature of the asset

  • at the date on which the contract for the addition or work was made, or
  • where there is no contract, the date on which the work was commenced.Where expenditure has been incurred but the work has not been carried out, and either

  • that sum or any part of it has been paid, or
  • the asset is disposed of on the terms that the person disposing of it undertakes to meet that expenditure, and subsequently does so,the relevant date for the purposes of the apportionment is the date the vendor originally incurred that expenditure. This is normally the date of the contract. The wording of the comparable provision for indexation, TCGA92/S54 (4)(b), is not identical, see CG17251+. However, in practice the same date can normally be adopted.