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HMRC internal manual

Capital Gains Manual

Land: part-disposals: estates comprising `natural' units

Where the land comprises a large estate and has been acquired by gift or inheritance, a valuation is often required for IHT purposes. In such cases, the normal practice is to split the estate into `natural units’. This practice was supported by the House of Lords in the case of Duke of Buccleuch and another v IRC (an Estate Duty case). Each of these `natural units’ should be regarded as a single asset for Capital Gains Tax purposes.