Revenue Note for Guidance

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Revenue Note for Guidance

653 Restriction of relief for losses, etc in relation to relevant disposals

(1) In computing a person’s liability to capital gains tax, allowable losses made on the disposal of an asset which is not development land (that is, an ordinary disposal) may not be set off against chargeable gains made on the disposal of development land.

(2) In computing a person’s liability to capital gains tax, allowable losses made on disposals of development land may be set off against chargeable gains on such disposals and on ordinary disposals. However, where a company sets off an allowable loss on a disposal of development land against a chargeable gain on such a disposal, the same loss cannot be deducted again in calculating the company’s corporation tax liability in respect of chargeable gains.

Relevant Date: Finance Act 2019