The time limits for HMRC to make an assessment are extended where the loss of tax relates to a disposal made under contract where completion is delayed.
Normally the time limits for HMRC to make an assessment in relation to capital gains are based on the tax year or accounting period in which the disposal takes place for capital gains tax/corporation tax as this is when the gain (or loss) is deemed to arise.
So when does a disposal under a contract occur for capital gains purposes? The general rule is that the date of disposal is the date on which the contract is made1. If the contract is conditional, the date of disposal is the date that the contract becomes
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