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HMRC internal manual

Capital Gains Manual

Groups: modification of compulsory purchase roll-over relief rules


The rules in TCGA92/S247 for roll-over relief on the compulsory acquisition of land are also modified for groups of companies. Guidance on Section 247 is at CG61900+.

TCGA92/S247 (5A)

There are two modifications to the Section 247 rules.

  • The same person rule referred to in CG45948+is applied to Section 247 by a new subsection (5A). This means that relief will be due, if all the other conditions are met, where land held by one group company is disposed of by the application of a power of compulsory purchase and replacement land is acquired by another group company.
  • Land acquired at no gain/no loss from another group company cannot be replacement land for roll-over relief purposes. Section 247(5A) applies Section 175(2C), see CG45953, to compulsory acquisition cases.