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HMRC internal manual

Capital Gains Manual

Death and Personal Representatives: Personal representatives and their liabilities: Personal representatives: special personal representatives

Special personal representatives are appointed in addition to ordinary personal representatives when

  • the deceased was a tenant for life of a trust containing land


  • that land was not held on trust for sale but was settled land within the Settled Land Act 1925


  • after the death of the life tenant the land continues to be settled land within the Settled Land Act 1925.

The special personal representatives deal only with this settled land and act totally independently of the ordinary personal representatives. They have to account for any Inheritance Tax arising in respect of this settled land and may have to make disposals of land to raise funds to do this. Once they have settled that liability it is their duty to convey the land to the new tenant for life entitled following the death of the previous tenant for life.