Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Transaction definition

What does Transaction mean? A transaction describes a legally binding dealing or arrangement by which assets, securities, services or obligations are created, transferred, varied or extinguished, whether as a single step or a series of steps. In practice this includes corporate acquisitions and disposals, real estate conveyancing, lending and taking security, restructurings, derivatives and other commercial dealings. In capital markets, a transaction commonly means the purchase, sale, subscription or underwriting of a particular investment. The term is a descriptive umbrella used across multiple legal contexts rather than a term with a single statutory meaning. Specific legislation, regulatory rules and contracts may define “transaction”...

CAA 2001 s198/s199 fixtures elections in UK property transactions: apportionment of consideration, fixed value requirement, buyer/seller positions, HMRC requirements, deadlines and pitfalls

Published by a LexisNexis Tax expert

Practice notes

FORTHCOMING CHANGES:

At Budget 2025, the government confirmed Finance Bill 2026 measures:

Main pool writing‑down allowances fall from 18% to 14% from 1 April 2026 (CT) and 6 April 2026 (IT), impacting companies and unincorporated businesses, including pre‑FYA expenditure.
A 40% first‑year allowance for qualifying main rate spend incurred from 1 January 2026, with fewer restrictions than other FYAs; it mainly helps costs outside the £1m AIA or existing FYAs, applies to all businesses, includes assets used for leasing (not overseas), and excludes cars and second‑hand assets.
100% green FYAs for zero‑emission cars and EV charging points extended to 31 March 2027 (CT) and 5 April 2027 (IT).

The Practice Note outlines section 198/199 CAA 2001 elections for fixtures transferred on property sales or new leases. Default treatment is a just and reasonable apportionment, or the parties may jointly fix the value within two years. Elections are irrevocable, capped at the seller’s original cost, require clear identification of the land, fixtures and amount, and only apply where the seller has pooled qualifying expenditure or claimed a first‑year allowance. Invalid or missing elections risk clawback for sellers and may leave buyers unable to claim without a timely First‑tier Tribunal determination...

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Steven Bone

Gateley Legal

Steven is a tax-qualified chartered surveyor. He has specialised in capital allowances for more than 25 years, and more recently land remediation relief and R&D tax incentives. In his role as director at Gateley Capitus, Steven works with businesses that are buying, building or refurbishing commercial property, cleaning-up contaminated land and buildings or undertaking R&D activity to help them pay the right amount of tax by optimising the tax reliefs available to them.Prior to joining Gateley Capitus, Steven held senior roles in the Big 4, specialist boutique and national mid-tier accountancy firms. He is a fellow of the Royal Institution of Chartered Surveyors (RICS) and the Association of Taxation Technicians.Alongside daily practice, Steven is a tax incentives writer and speaker for property investment and innovation activity. ...

Web page updated on 21/05/2026

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