Taxation of Chargeable Gains Act 1992 Schedule 4ZZC paragraph 17

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

Paragraph 17 of Schedule 4ZZC sets out how to calculate the balancing chargeable gain or allowable loss when a relevant high value disposal of an interest in UK land does not fall within Cases 1, 2 or 3, or where the taxpayer has made an election to use this method instead.

  • This paragraph applies to relevant high value disposals that do not fit neatly into the three standard computation cases, or where the taxpayer has elected to use this alternative calculation method
  • The balancing gain or loss is computed by taking the overall gain or loss on the disposal and then subtracting any amounts already charged under the Annual Tax on Enveloped Dwellings (ATED)-related gains regime or attributed to periods of non-residence
  • The calculation ensures there is no double counting โ€” amounts already subject to tax under other provisions are stripped out so that only the residual, or balancing, element is brought into charge
  • Where an election has been made to use this computation method, it applies as an alternative to the standard case-based calculations, giving the taxpayer a degree of flexibility in how the gain is allocated across different charging regimes

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