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Official guidance
Capital Gains Manual

CG37873P · Capital Gains Manual: Trusts and Capital Gains Tax: Transactions creating separate settlements: Conventional use of special powers of appointment

  • CG37874 · Separate settlements: conventional use of special powers of appointment
  • CG37875 · Separate settlements: intention of trustees
  1. Capital Gains Manual: Trusts and Capital Gains Tax: Transactions creating separate settlements: Conventional use of special powers of appointment: Contents
  2. Separate settlements: intention of trustees

CG37875 | Separate settlements: intention of trustees

From HM Revenue & Customs · Capital Gains Manual

Swires v Renton, L3278, shows that some attention may be given to the intention of thetrustees. However the judge did not accept the Special Commissioner’s view that one couldlook at the subjective view of the trustees in exercising their power. All that could belooked at is what they did and the actual wording of the documentation.

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