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HMRC internal manual

Capital Gains Manual

Chattels: sets of assets: identifying a set

The special rules which CG76631 tells you about only apply in cases involving a set of chattels (tangible moveable property).

The dictionary definition of a set is a number of things which belong together because they are essentially similar or complementary to each other.

However, that definition does not entirely fit with the rules in TCGA92/S262(4).  The dictionary definition would treat all the seats in a cinema or theatre as similar to each other but these would not be a set for chargeable gains purposes.

We, therefore, take the view that a number of articles will only form a set if

  • they are essentially similar and complementary


  • their value taken together is greater than their total individual value.

The fact that a number of chattels have been included as one lot at an auction, for example, or have been disposed of to the same person(s) is not conclusive that those chattels comprised a set.

While the test for a set may not be satisfied when a complete collection of assets is split up and disposed of, you may be able to identify smaller sets within the collection.  If you can, and if the other conditions are satisfied (see CG76631), you can regard each of these small sets as single assets.

Where necessary, any apportionment should be made using the rules in TCGA92/S52(4).