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HMRC internal manual

Capital Gains Manual

Leases: commutation of rent or variation of terms: assessing time limits

TCGA92/SCH8/PARA 3(4) provides that any necessary adjustments of tax shall be made in order to give effect to the rule in CG71354. Such adjustments could be by way of assessment or by way of discharge or repayment of tax.

An assessment, or further assessment, can be made even if the year of assessment in which the premium is deemed to have arisen ended more than six years before that in which the capital sum is received. The only circumstance in which an assessment will not be possible is where the lease was granted before 6 April 1965.