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HMRC internal manual

Capital Gains Manual

Venture Capital Trusts: value of one asset derived from another asset

TCGA92/S101C (5)For the purposes of Section 101C an asset acquired by a company under TCGA92/S171(1) shall be treated as the same as an asset it owned at a later date if the value of the second asset is derived from the first asset. In practice, this is most likely to involve the acquisition of the freehold reversion interest in land by a company which previously owned a leasehold interest.