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TCGA92/S22 (1)(d)

»Ê¹ÚÌåÓýapp decision in Chaloner v Pellipar Investments Ltd (TCB7/96) distinguishes disposals of an interest in land that fall within TCGA92/S22 (1) (particularly capital sums received for the use or exploitation of assets, see CG12945) from those that do not. »Ê¹ÚÌåÓýapp importance of the distinction is that the time of a disposal that falls within Section 22(1) is given by Section 22(2) as the time at which any capital sum is received, see CG12960. »Ê¹ÚÌåÓýapp time of most other disposals of land is determined by TCGA92/S28, see CG14250P onwards.

Disposals in which the owner's title to the land is affected, for example by the grant of a lease, do not fall within Section 22(1). Disposals in which the owner's title is not affected, for example the grant of a licence, a profit or an easement, do fall within Section 22(1).