Taxation of Chargeable Gains Act 1992 Schedule 4ZZB paragraph 12

Disposal involving one or more relevant high value disposals

Paragraph 12 of Schedule 4ZZB sets out how to calculate the chargeable gain or allowable loss when a disposal includes one or more relevant high value disposals, ensuring that the appropriate portion of the overall gain or loss is attributed to the high value element.

• When a disposal gives rise to both a relevant high value disposal and a non-high value element, the overall gain or loss must be apportioned between those elements.
• The portion of the gain or loss attributable to the relevant high value disposal is calculated on a just and reasonable basis.
• This apportionment mechanism ensures that only the part of the gain or loss properly relating to the high value disposal is subject to the special rules for such disposals.
• The provision was introduced by the Finance Act 2019 and forms part of the broader framework for taxing gains on high value disposals of interests in UK land.