Taxation of Chargeable Gains Act 1992 Schedule 4ZZC paragraph 10

Computation of residential property gains or losses on relevant high value disposal not within Case 1, 2 or 3 (or where an election is made)

Paragraph 10 of Schedule 4ZZC sets out how to calculate the chargeable gain or allowable loss on a relevant high value disposal of residential property where the disposal does not fall within Cases 1, 2 or 3, or where the taxpayer has made an election to use a different computation method.

• This paragraph applies to disposals of high value residential property that do not fit neatly into the three standard computation cases, or where an election has been made to opt out of those cases.
• The computation uses a time-apportioned approach to identify the proportion of the overall gain or loss that relates to periods of ATED-related ownership, ensuring only the relevant portion is charged under the ATED-related capital gains tax regime.
• The method requires the taxpayer to identify the total gain or loss on the disposal and then apportion it by reference to the number of days in ATED-related ownership compared to the total period of ownership.
• This calculation was amended by the Finance Act 2019 to align with wider changes to the high value residential property disposal rules.

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