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HMRC internal manual

Capital Gains Manual

Residence of trustees: pre 5 April 2007: general administration

The activities of an agent appointed by the trustees to manage the day to day affairs ofthe trust, for example, to look after the investments, should not normally have been takeninto account in determining where the general administration of the trusts was carried on.However, where a trust claimed to be non-resident, the general administrative duties whichwould normally fall within the responsibility of trustees (as opposed to any agentappointed by them) must in fact have been ordinarily carried on outside the United Kingdomby the trustees.