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HMRC internal manual

Capital Gains Manual

Persons chargeable: trustees and personal representatives

TCGA92/S62 (3) & TCGA92/S69 (1)

Trustees and personal representatives are treated as a single and continuing body of persons regardless of any changes in the persons acting. Assessments are to be made on those in office at the time of the assessment, not those in office when the gain was made, see CG35400.

  • Trustees are chargeable to Capital Gains Tax unless the trustees, or a majority of them, are neither resident nor ordinarily resident* in the UK and the general administration of the trust is carried on abroad, see CG33370+.
  • Personal representatives are chargeable to Capital Gains Tax if the deceased was resident or ordinarily resident* in the UK when he or she died, see CG30650.

  • For 2013/14 and later tax years ordinary residence does not need to be considered.