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HMRC internal manual

Capital Gains Manual

Land: compulsory purchase of land: revenue/capital elements

TCGA92/S245 (1)

But for the provisions of TCGA92/S245 (1), the amount of compensation received as the result of a compulsory purchase of land would, in law, be one indivisible sum. This is the case even though the compensation may have been calculated by reference to a number of factors, including, for example, temporary loss of profits. However, Section 245(1) allows the compensation to be split into `revenue’ and `capital’ elements for tax purposes. It also allows the `capital’ element to be apportioned under TCGA92/S52 (4), see CG14771.