Commentary

C2.403 Non-apportioned expenditure

Capital gains tax
Capital gains tax | Commentary

C2.403 Non-apportioned expenditure

Capital gains tax | Commentary

C2.403 Non-apportioned expenditure

The general apportionment rule is not applied to expenditure which, on the facts, is wholly attributable to what is disposed of, or to what remains undisposed of; for such expenditure, no apportionment is required1.

The practical effect of this provision may be to allocate an undue proportion of expenditure to the part of the asset disposed of, because the unapportioned expenditure may enhance the amount of consideration received, and this will in turn increase the fraction:

in relation to the apportionable expenditure.

Example 1

CC purchased a piece of land in February 2011 for £100,000. In June 2014, he incurred expenditure

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