CG36457 | Life interests and interests in possession: Death of person with interest in possession: reversion to settlor

TCGA92/S73 (1)(b)

In the unusual case where the property reverts to the settlor on the death of the person entitled to the interest if IHTA84/S54 applies no Inheritance Tax is chargeable. There is, therefore, no reason for exempting permanently any gain accrued up to that date but it is not chargeable to Capital Gains Tax on that occasion. The deemed disposal and re-acquisition is on a no gain/no loss basis.

From 22 March 2006 this only applies to certain kinds of interest in possession, see CG36525.