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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
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Compensation: displaced tenants: licensed premises: compensation payments

If the tenant surrenders the tenancy at the expiry of the notice period, or surrenders voluntarily without the issue of a notice to quit, the compensation payment will usually consist entirely of the `basic’ element and will be outside the scope of Capital Gains Tax. This follows from the decision in Drummond v Brown, 58TC67, see CG72351-CG72352.