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HMRC internal manual

Capital Gains Manual

Arrival in and departure from the UK: establishing the correct time when a gain arises: splitting a single contract

In this type of case, what would normally have been included in a single contract for sale is split into two contracts. For example, a farmer owning a farmhouse and associated farmland emigrates; he claims to have sold the farmhouse prior to the date his residence position changes (possibly to give immediate access to capital) and the farmland after the date his residence position changes and this points to the fact that two separate contracts have been entered into. Relief under TCGA92/S222 is claimed on the disposal of the farmhouse. In such cases, it may be possible to sustain an argument that, in reality, there is only a single disposal for capital gains purposes, the date of disposal of the farmland and the farmhouse being the same: that is to say, the earlier of the two dates.