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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Trustees: general

TCGA92/S69 (3)

Where part of the property comprised in a settlement is vested in one set of trusteesand part in another (in particular, where settled land within the meaning of the SettledLand Act 1925 is vested in the tenant for life and investments representing capital arevested in trustees of the settlement), they are to be treated as a single body oftrustees, even if they act separately. On the other hand, if there are two separatesettlements, the trustees of each are treated as separate bodies. FA 2006 introduced theconcept of a sub-fund settlement, where there has been an election that a discretesub-fund should be treated for most purposes of CGT and Income Tax as a separatesettlement, see CG33330+.