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HMRC internal manual

Capital Gains Manual

Leases: Assessments for periods ended more than 6 years previously

Where the year of assessment (or accounting period in the case of a company) in which the original lease was granted ended more than six years previously an assessment can still be raised under TCGA92/SCH8/PARA3 (4). TCGA92/SCH8/PARA3 (4) is one of the `provisions of the Taxes Acts allowing a longer period in any particular class of case’ which is an exception to the normal six year time limit in TMA70/S34. If this was not so, TCGA92/SCH8/PARA3 (4) would be largely ineffective, since the majority of leases are for periods well in excess of six years, and the majority of occasions when it will apply will involve leases granted more than six years previously.