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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Annual exempt amount: exploitation: warning

You should remember that not every fragmented disposal is an avoidance device and youmay find that there were good commercial reasons for, say, the disposal of land in anumber of tranches. Similarly, a gift may well be genuine even though there is an overalltax benefit. IT IS ESSENTIAL TO ASCERTAIN THE FULL FACTS BEFORE ADVANCING THE ARGUMENTSOUTLINED BELOW.