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HMRC internal manual

Capital Gains Manual

Annual exempt amount: exploitation: fragmentation

A simple example is the disposal of a single holding of land in two parts to the same purchaser. One part is sold under a contract made on or before 5 April; the other part is sold under a separate contract made on or after 6 April. When the sales are completed (often on the same day) the effect of TCGA92/S28 (time of disposal and acquisition) is to determine the dates of disposal as the dates on which the contracts were entered into, so that two annual exemptions are available.