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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Introduction and computation: annual exempt amount: exploitation of annual exempt amount: Annual exempt amount: exploitation: fragmentation

The vendor and the purchaser may have agreed at the outset that the whole asset should be sold. If we can establish that there was a single contract, possibly oral, to this effect and can demonstrate that was the agreement under which the disposal took place, the date of the single contract will be the date of disposal. Unless the asset is land, it is not significant that the agreement is oral, provided that it is unconditional.

This argument used to apply to land, on the authority of Thompson v Salah 47TC559. However, the Law of Property (Miscellaneous Provisions) Act 1989 provides that contracts in respect of land made on or after 27 September 1989 must be made in writing.