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HMRC internal manual

Capital Gains Manual

Land: part-disposals: interaction with 6/4/65 valuations

Where the special practice in CG71850-71851 applies, the taxpayer can elect under TCGA92/SCH2/PARA17 for a valuation at 6 April 1965. Such an election in respect of a particular part-disposal will not mean that the taxpayer is committed to paragraph 17 Schedule 2 treatment in respect of a subsequent disposal, or part-disposal, of the land. This is because under the special practice, the land sold is treated as a separate asset.

Similarly, if the part-disposal is of land with development value, and hence TCGA92/SCH2/PARA9 applies, the mandatory valuation at 6 April 1965 need only apply to the part sold.