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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
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Land: exchange of joint interests: introduction

The exchange of interests in land which are jointly owned by two or more persons constitutes a disposal by each owner for capital gains tax purposes. In some cases the exchange is made simply to rationalise the ownership of the land and to make it easier to deal with. The exchange may give rise to a charge to capital gains tax, and this is the case where no money changes hands.

An Extra-Statutory Concession, ESC/D26, published in 1984 provides a form of roll-over relief in certain circumstances to facilitate rearrangements of holdings of land, see CG73015+. The ESC provides relief in relation to disposals prior to 6th April 2010.

In relation to disposals on or after 6th April 2010 the relief is given by TCGA 1992/S248A - 248E, see CG73002+.