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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Land: part-disposals: procedure

In each case in which the practice in CG71851 is applied, a record should be maintained toensure

  • that the total amounts allowed do not exceed the original cost or value of the entire holding; and
  • that where TCGA92/SCH2/PARA9 or TCGA92/SCH2/PARA17 are applied, an allowable loss does not accrue where there was in fact an overall gain.

Ultimately, the total costs of the parts disposed of must not exceed the total cost ofthe entire holding.