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Official guidance
Capital Gains Manual

CG37100P · Capital Gains Manual: Trusts and Capital Gains Tax: Becoming absolutely entitled: general: Effects of person becoming absolutely entitled

  • CG37101 · Absolute entitlement: effects: expenses
  • CG37102 · Absolute entitlement: effects: death of life tenant
  • CG37103 · Absolute entitlement: effects: sales by trustees after
  • CG37104 · Absolute entitlement: distribution of assets not as strict entitlement
  • CG37105 · Absolute entitlement: distribution of assets not as strict entitlement
  1. Capital Gains Manual: Trusts and Capital Gains Tax: Becoming absolutely entitled: general: Effects of person becoming absolutely entitled: contents
  2. Absolute entitlement: distribution of assets not as strict entitlement

CG37105 | Absolute entitlement: distribution of assets not as strict entitlement

From HM Revenue & Customs · Capital Gains Manual

It is however possible that the principles of Warrington v Brown may be applicable inthese two situations, see CG37410 - CG37411, so that there is no second disposal followingshortly after the Section 71 (1) occasion. If the trustees and beneficiaries seek to applythose principles, no objection should be made, although any attempt to treat a subsequentdisposal of an asset on an inconsistent basis should be resisted.

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