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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Settlor trusts: computations: foreign gains special cases

TCGA92/S79 (7)

The gains attributed to the settlor may include a gain accruing to a non-resident company which is treated as accruing to the trustees of the settlement under TCGA92/S13, see CG57200+.