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HMRC internal manual

Capital Gains Manual

Land: disposals: unascertainable deferred consideration: part chargeable as income

ITA2007/S752-772 and CTA2010/S815-833

Where an agreement for the sale of land provides for additional consideration to be received on the happening of some future event, the possibility of liability under the sections (transactions in land rules) above, see BIM60300+, should be considered.

The most common situations which will be encountered are where the receipt of additional consideration is dependent on

  • The purchaser obtaining planning permission in respect of the land (if this is the only condition, liability under the sections above is unlikely), or
  • The purchaser developing the land by constructing housing, offices, shops or industrial premises (liability under the sections above is a distinct possibility).