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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Land: part-disposals: composite disposals

Where a disposal of land includes the whole or part of two or more separate assets, the composite disposal should, if possible, be dealt with in a single computation. Separate computations are however needed if

  • one or more of the assets is a short lease to which the wasting asset rules apply, see CG71140+;
  • time-apportionment, see CG15500+, applies to assets included in the disposal which were acquired at different times before 6 April 1965; or
  • time-apportionment applies to one or more, but not all, of the assets included in the disposal.Where separate computations are needed in respect of a composite disposal, the consideration should be apportioned on a just and reasonable basis between the various assets under TCGA92/S52 (4), see CG14771+. If agreement on the apportionment cannot be reached, advice should be obtained from the Valuation Office Agency, see CG74150+.