I want to determine the residential element on the disposal of a let cottage which was part of an inherited farm.
I read Michael Blake’s article ‘Peculiar entities’ (Taxation 3 November 2016 page 12) which asks ‘what is the asset?’ and I direct readers to HMRC’s Capital Gains Manual at CG71800 which states:
‘A single acquisition of land with or without buildings whether by purchase gift or inheritance should normally be regarded as the acquisition of a single asset for capital gains tax purposes.’ So the disposal of the let cottage is a part disposal of the farm although this can be abandoned if advantage is taken of statement of practice D1 – fictional separate asset basis.
Michael’s article also mentions that in the context of the old taper relief provisions if statement of practice D1 was adopted...
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