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In respect of UK property businesses, post-cessation receipts are subject to income or corporation tax. For income tax purposes the legislation clarifies that the charge is on the full amount received in the particular tax year and the person liable to tax is the person receiving or entitled to receive the amounts¹.

However, there is no charge in respect of any post-cessation amount that is otherwise subject to income tax or corporation tax².

Similarly, the rules for trades that allow for post-cessation expenditure to be set off against post-cessation receipts (see Division B2.8) apply equally to UK property businesses. In addition post-cessation receipts can be carried back to the date of cessation if an election is made within the normal self assessment time limit for elections (one year after the normal filing date) for income tax purposes, and within two years of the end of the accounting period in which the receipt is received for corporation tax purposes³.

If, immediately before a person permanently ceases to carry on an unincorporated