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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Mineral leases: terminal loss relief: disposal of land

TCGA92/S202 (7)

If there is an actual disposal of the land prior to the expiry of the mineral lease, or a deemed disposal otherwise than as a result of a claim under TCGA92/S202 (3), and an allowable loss arises, that loss can be utilised in the normal way. However, the person making the disposal, providing they are eligible to make a claim, see CG71742, can elect to treat this loss as a `terminal loss’ for the purposes of TCGA92/S202 and can carry back the loss in accordance with TCGA92/S202 (9)-(11), see CG71751.