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HMRC internal manual

Capital Gains Manual

Short leases: disposal: 'period of ownership'

TCGA92/SCH8/PARA1

Unless there is some specific statutory provision (as in for example, TCGA92/S152 (9)), the term ‘period of ownership’ normally means the entire period of ownership, even if part of that period falls before 31 March 1982, or indeed before 6 April 1965.

However, in the context of TCGA92/SCH8/PARA1, if the allowable expenditure under Section 38(1)(a) is the ‘wasted’ 31 March 1982 value of the lease, the period of ownership begins on 31 March 1982. If this was not the case, there would be an element of ‘double wasting’ since the value at 31 March 1982 already takes into account the wastage which has occurred prior to that date.