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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Effects of residence/domicile: settlements

For settlements there were no relaxations to the residence rules equivalent to the concessions that applied for individuals for the years up to and including 2012-13. Thus any gains realised by trustees of a settlement between the date they became resident and the preceding 6 April are within the charge to tax. Similarly any gains realised between the date trustees cease to be resident and the following 5 April remain within the charge to tax. In addition trustees may be liable to an exit charge under TCGA92/S80 when they cease to be resident in the UK, see CG38215, or under TCGA92/S83 when they become treaty non-resident, see CG13440+ and CG38215.

Guidance on establishing the residence position of a settlement can be found in the Trusts, Estates and Settlement Manual see TSEM1461+.