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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
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Death of person with interest in possession: reversion to settlor

TCGA92/S73 (1)(b)

In the unusual case where the property reverts to the settlor on the death of theperson entitled to the interest if IHTA84/S54 applies no Inheritance Tax is chargeable.There is, therefore, no reason for exempting permanently any gain accrued up to that datebut it is not chargeable to Capital Gains Tax on that occasion. The deemed disposal andre- acquisition is on a no gain/no loss basis.

From 22 March 2006 this only applies to certain kinds of interest in possession, seeCG36525.