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HMRC internal manual

Capital Gains Manual

Roll-over relief: reorganisations of constituencies: successor association

Where the property is disposed of to a successor association, the existing association andthe successor association are treated for capital gains purposes as if the land disposedof was acquired from the existing association for a consideration of such an amount aswould secure that, on the disposal, neither a gain nor a loss accrued to the existingassociation. The successor association is treated as having incurred the same costs as theexisting association.

These rules apply also if the land is disposed of by the existing association to thesuccessor association through an intermediate body, that body being treated as havingincurred the same costs as the existing association and the successor association beingtreated as incurring the same costs as the intermediate body.