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HMRC internal manual

Capital Gains Manual

Land: development value: meaning of `land with development value'

This rule applies to all interests in land, for example it applies equally to leases and freehold interests. It can also apply even if planning permission had not actually been granted prior to the disposal, Watkins v Kidson, 53TC117. It also applies even if the land had `hope’ or `development’ value throughout the period of ownership, Morgan v Gibson, 61TC654.