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HMRC internal manual

Capital Gains Manual

Land: part-disposals: value shifting: xfer value from tenant to landlord

TCGA92/S29 (4)TCGA92/S29 (4) applies where all the following conditions are satisfied

  • the owner of a holding of land becomes the tenant of that land under a lease;
  • subsequently, there is a variation of the rights or liabilities under the lease (whether involving the grant of a new lease or not);
  • that variation is as a whole favourable to the landlord.An example of the application of TCGA92/S29 (4) to a lease of land is given at CG72012.