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HMRC internal manual

Capital Gains Manual

Basic terms of trust law as applied to CGT: sub-fund settlements: basic effects for CGT: giving advice

It is important that HMRC officers should avoid giving specific guidance to trustees onthe question whether an election should be made. Advice should be limited to telling themwhat is actually said in CGM and TSEM and the legislation. This is because although thelong-term consequences, in particular the removal of the four points in the bullets inCG33330, are greater fairness between different funds, and considerably greaterconvenience where there are discrete trustees, the short-term tax effects may be verycomplicated. In particular one has to consider the effects of there being a deemeddisposal for CGT purposes on the prescribed date, in particular on the base costs ofvarious assets (if appropriate after hold-over relief) and the position for CGT taperrelief.