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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Non-retrospective variations: deleting trust: personal representatives

In the simplest case example above, to the extent that the asset passes to B as assignee, the personal representatives should be regarded as making a disposal of that fraction of the asset at market value on the date of vesting. A capital gain or allowable loss may therefore accrue to them on that proportion of the asset. The remaining interest in the asset should be regarded as passing under cover of TCGA92/S62 (4) at an appropriate proportion of probate value.