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HMRC internal manual

Capital Gains Manual

Disposals by trustees: reliefs: private residence relief

The disposal by trustees of a dwelling-house which has been the only or main residence of a beneficiary or beneficiaries entitled to occupy it under a settlement may well give rise to a chargeable gain or allowable loss; the conditions for exemption under TCGA92/S225 are described in CG65400+. If a life tenant or other beneficiary, who has satisfied those conditions from the time of acquisition of the house by the trustees, or 31 March 1982 if later, subsequently becomes the absolute owner of the residence, no chargeable gain or allowable loss will arise on that event under TCGA92/S71 (1).