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HMRC internal manual

Capital Gains Manual

Residence of trustees: pre 5 April 2007: general administration

Where there was more than one trustee, and one of them was a professional trustee withinCG33390 - CG33391, and a majority of the trustees was, or was treated as, not resident inthe United Kingdom, the general administration of the trust was to be regarded asordinarily carried on outside the United Kingdom.