Section 25ZA | Postponing gain or loss under section 25(3): interests in UK land ^F1

(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.