Part 18Transactions in land

Exemptions

827Gain attributable to period before intention to develop formed

1

This section applies if—

a

income is treated as arising because the condition mentioned in section 819(2)(d) is met (land developed with sole or main object of realising a gain from its disposal when developed), and

b

part of the income is fairly attributable to a period before the intention to develop was formed.

2

No liability to corporation tax arises as a result of this Part in respect of that part of the income.

3

In applying this section account must be taken of the treatment under Part 3 of CTA 2009 (trading income) of a company which appropriates land as trading stock.