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HMRC internal manual

Capital Gains Manual

Residence of trustees: pre 5 April 2007: professional trustees

TCGA92/S69 (2)

Special treatment was provided for foreign settlors in order to avoid discouraging them from putting their affairs into the hands of United Kingdom banks and professional trustees. If a person (for example, a bank, solicitor, accountant or stockbroker), carried on a business which included the management of trusts and acted as trustee in the course of that business, they were to be treated in relation to that trust as not resident in the United Kingdom if the whole of the settled property derived from a person who had not been, at the time of its provision (or, in the case of a will trust or intestacy, at the time of the death) domiciled, resident or ordinarily resident in the United Kingdom.