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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Land: development value: 6/4/65 valuation

TCGA92/SCH2/PARA9 (2)Where land with development value, see CG72603-72605, is sold, and that land was held at 6 April 1965, time-apportionment, see CG15570+, is not appropriate since the growth in value of the land over the period of ownership is unlikely to have been uniform. Hence, the land is deemed to have been disposed of and immediately reacquired at its market value on 6 April 1965. That value then becomes the cost for the purposes of TCGA92/S38 (1)(a) (but subject to the rebasing rules in TCGA92/S35, see CG16700+). This rule must be applied if the conditions set out in CG72603-72605 are satisfied.