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HMRC internal manual

Capital Gains Manual

Land: what is land?: chattels and fixtures

For a definition of chattels see CG76550+.

Chattels which have been brought onto land may become fixtures. This will normally occur when either the chattels are intended to remain permanently on the land or are attached to the land (or a building on it) in a permanent way.

Where a chattel has become a fixture, it should not be treated as a separate asset unless it is physically detached from the land and sold independently. Where this is the case it is the point at which the fixture becomes detached from the land that it becomes a chattel again. Not, if different, the date on which it is sold.

Where fixtures have been attached to the land by a tenant again they should not be treated as separate assets; they merge with the land. Certain tenants however are entitled by law to remove certain fixtures that they have attached to land at the end of their tenancy. However unless and until the tenant exercises his right of removal the fixtures continue to form part of the land and remain the property of the landlord.