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CG39140 | TCGA92/Sch4B - transfer of value linked with trustee borrowing

From HM Revenue & Customs · Capital Gains Manual

TCGA92/Sch4B/para5

A transfer of value is linked with trustee borrowing if there is outstanding trustee borrowing at the material time, CG39125.

There is outstanding trustee borrowing if:

  • a loan obligation, CG39130, is outstanding, and

  • there are proceeds of trustee borrowing, CG39135, that have not been

  • applied for normal trust purposes, CG39145, or

  • been taken into account in relation to an earlier transfer of value.

The amount taken into account in relation to an earlier transfer of value is the lower of:

  • the amount of the value transferred, or

  • the amount of the outstanding trustee borrowing at the material time in relation to the earlier transfer.