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HMRC internal manual

Capital Gains Manual

Land: valuation: apportionments: amount and method of apportionment

The Valuation Office Agency can provide advice on two matters

  • the apportionment of any consideration where one or more of the assets is an interest in land in the United Kingdom


  • the appropriate method of apportionment between the various assets.

If agreement cannot be reached about an apportionment of any consideration between different assets that include land it may be necessary to refer the dispute to the Lands Tribunal see CG74500+.

TCGA92/S52 (4) requires that any necessary apportionment is to be ‘just and reasonable’, see CG14771. Where land is involved any judgement about what is just and reasonable must take into consideration the value of that land, therefore the Lands Tribunal has authority to consider any land valuations within its jurisdiction needed to come to a judgement about an apportionment. You should follow the guidance at CG74500+.