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HMRC internal manual

Capital Gains Manual

Trusts: outline of CGT for trusts: transfers out

If a beneficiary becomes absolutely entitled to any of the settled property as against thetrustee, there is at that moment a deemed disposal and reacquisition of the propertyconcerned at market value by the trustees. See CG37000. The trustees now hold the asset asbare trustees, see CG34300 onwards. If this is the result of the death of a person with aninterest in possession, then some or all of that gain may be exempted. See CG36454.

Unused losses may in certain circumstances pass to the beneficiaries. See CG37200.