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HMRC internal manual

Capital Gains Manual

Leases: merger: interaction with time- apportionment

TCGA92/SCH2/PARA16 (9)If the original lease was acquired before 6 April 1965 and the time-apportionment rules apply, see CG15500+, in applying the time-apportionment formula to the gain the whole of the expenditure attributable to the freehold is deemed to have been incurred on the date of the earlier acquisition of the leasehold, TCGA92/SCH2/PARA16 (9).