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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Land: disposals: unascertainable deferred consideration: first intention

If ICTA88/S776 etc apply, the amount chargeable under that Section is normally the difference between the total consideration received for the disposal of the land and the market value of the land on the date that intention to develop it was first formed - ‘the first intention date’ - see BIM60350. ITA2007/S765 and CTA2010/S827 refer to the part of the income fairly attributable to the period before the intention to develop was formed.

The first intention date is determined purely as a question of fact. If possible, that date should be agreed with the taxpayer. Having established that date, the market value of the land on that date will then need to be determined. That valuation should be obtained by reference to the Valuation Office Agency, see BIM60360.