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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Non-retrospective variations: assets still vested in PRs: hindsight

When the assets finally vest, hindsight should be applied to enable a Capital Gains computation to be prepared. Only the chargeable assets vesting in the legatee should be considered for this computation. For each of these assets the acquisition cost will be the appropriate market value of that asset at the date of death. The disposal consideration should be arrived at by apportioning the valuable consideration received between both the chargeable and non-chargeable assets vesting from the estate. In carrying out this apportionment you may accept an apportionment

  • based on the probate values of the assets involved
  • based on the values of the assets at the date of the variation


  • based on the values of the assets at the date of vesting unless there is evidence to suggest that a particular basis has been chosen in order to exploit differences in valuations between those dates.