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HMRC internal manual

Capital Gains Manual

Land: part-disposals: procedure

If it is not possible to agree the apportionment in any particular case, that case will have to go to appeal on the strict basis, that is on the basis of applying the A/A+B formula in TCGA92/S42. Any such appeal will lie to the Lands Tribunal, not to the First-tier Tribunal, see CG74500+.