CTA 2010, Part 8ZB also extends to what might be called ‘indirect disposals’ of UK land.

Where:

(a)a person realises a profit or gain from a disposal of any property which (at the time of the disposal) derives at least 50% of its value from UK land,

(b)the person is a party to, or concerned in, an arrangement (¶712-410) concerning some or all of such land (the project land), and

(c)the main purpose, or one of the main purposes of the arrangement, is to deal in or develop the project land, and realise a profit or gain from a disposal of property deriving the whole or part of its value from that land,

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