BIM60355 - Transactions in land: Common situations: 'Slice of the action' contracts: Identification
The vendor, and their advisors, may be unaware that the transactions in land anti-avoidance rules are applicable to 鈥榮lice of the action鈥� contracts (see BIM60350).
Cases are frequently identified by HMRC Officers when the staged contingent payments are received, following development, and capital gains 鈥榩art disposal鈥� computations are submitted.
Any case where an Officer considers that the anti-avoidance provisions apply must be submitted to CTISA (Technical) before the matter is raised with the taxpayer or agent.