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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Basic terms of trust law applied to CGT: settlor: up to 5 April 2006

Normally the same person was the settlor for both Income Tax and Capital Gains Tax. But this was not the case where a person had assigned a right to income. Such an assignment could not have affected the identity of the settlor for Capital Gains Tax purposes. There are also certain other circumstances where the settlors may be different, in particular where there has been a Deed of Family Arrangement varying a will, (see CG31400+).