Taxation of Chargeable Gains Act 1992 Schedule 4ZZC paragraph 19

Relevant high value disposal and "other" disposal are comprised in the disposal of land

Paragraph 19 of Schedule 4ZZC deals with how to apportion the gain or loss when a single disposal of land includes both a relevant high value disposal (subject to the ATED-related CGT charge) and an "other" disposal (not subject to that charge).

• When a disposal of land comprises both a relevant high value disposal and an "other" disposal, the overall gain or loss must be split between the two parts.
• The apportionment is carried out on a just and reasonable basis, reflecting the extent to which the gain or loss is properly attributable to each part of the disposal.
• The portion attributed to the relevant high value disposal is subject to the ATED-related capital gains tax charge, while the portion attributed to the "other" disposal falls under normal CGT rules.
• This provision was introduced by the Finance Act 2019 as part of the reforms to the ATED-related CGT regime for high value residential property held by certain non-natural persons.

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