Taxation of Chargeable Gains Act 1992 Schedule 4ZZB Paragraph 20

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

Paragraph 20 of Schedule 4ZZB deals with how to calculate the ATED-related chargeable 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 land is disposed of and part qualifies as a relevant high value disposal while another part is an "other" disposal, the overall gain or loss must be apportioned 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 ATED-related CGT rules apply only to the portion of the gain or loss allocated to the relevant high value disposal element, not to the "other" disposal element.
• This provision was introduced by the Finance Act 2019 and ensures that mixed disposals of land are split fairly so that only the appropriate share falls within the higher ATED-related CGT charge.