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Official guidance
Capital Gains Manual

CG37600P · Capital Gains Manual: Trusts and Capital Gains Tax: Becoming absolutely entitled: particular cases: Mergers of interests

  • CG37610 · Absolute entitlement: mergers of interests: non-mergers
  • CG37620 · Absolute entitlement: life interest released in favour of remaindermen
  • CG37630 · Absolute entitlement: purchase by one beneficiary of other interest
  • CG37640 · Absolute entitlement: purchase of life interest and reversion
  • CG37641 · Absolute entitlement: mergers of interests: examples
  1. Capital Gains Manual: Trusts and Capital Gains Tax: Becoming absolutely entitled: particular cases: Mergers of interests: contents
  2. Absolute entitlement: purchase of life interest and reversion

CG37640 | Absolute entitlement: purchase of life interest and reversion

From HM Revenue & Customs · Capital Gains Manual

Where a person, who has acquired a life interest or remainder in settled property for a consideration in money or money’s worth, subsequently acquires the other interest (also for a consideration in money or money’s worth) and so becomes absolutely entitled as against the trustees to the settled property, there is an `occasion of charge’ on

  • the trustees under TCGA92/S71 (2), and

  • the person who acquired the interest under TCGA92/S76 (2), see CG38040.

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