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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Basic terms of trust law as applied to CGT: separate beneficiaries

The fact that the same person may benefit from several separate clauses of a will does not prevent there from being several settlements. However if at least one of these clauses provides discretionary trusts this may be a pointer to there being one settlement. The reason is that the trustees would probably be expected to consider the interests under the other clauses in deciding how to allocate the income of the discretionary fund. If so they are clearly trustees of the will trust as a whole.