25ZAPostponing gain or loss under section 25(3): interests in UK land

1

This section applies if an interest in UK land is deemed to have been disposed of under section 25(3) by a person at any time.

2

The gain or loss that, but for this subsection, would have accrued to the person at that time is not to accrue at that time.

3

But, on a subsequent disposal by the person of the whole or part of the interest in UK land, the whole or a corresponding part of the gain or loss is treated as accruing on the subsequent disposal.

4

This gain or loss is in addition to any gain or loss that actually accrues on the subsequent disposal.

5

A disposal to which section 171 (transfers within a group) applies does not count as a subsequent disposal for the purposes of this section.

6

A person may elect for a disposal deemed to have been made under section 25(3) to be excluded from the operation of this section.

7

An election made by a company must be made within 2 years after the day on which the deemed disposal occurs.

8

In this section “interest in UK land” has the meaning given by section 1C.