Commentary

C2.1115 Apportionment of consideration

Capital gains tax
Capital gains tax | Commentary

C2.1115 Apportionment of consideration

Capital gains tax | Commentary

Compulsory acquisition of land

C2.1115 Apportionment of consideration

Compensation is payable on the compulsory acquisition of land1, and there is provision2 for the apportionment of such compensation. The fact that the acquisition is or could have been made compulsorily is disregarded, and so is any statutory provision which treats the purchase price compensation or other consideration as exclusively paid in respect of the land itself. The purchase price or compensation or other consideration for the acquisition may be apportioned3 and treated in part as a capital sum4 in compensation for loss of goodwill or for disturbance or otherwise, or may be apportioned in any other way5.

HMRC consider6 that the compensation can be apportioned into amounts in respect of the following:

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