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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Death of person with interest in possession: death of annuitant

If some part of the trust is appropriated as a separate fund out of which the annuity ispayable, then by virtue of TCGA92/S72 (4), only the assets of that fund are involved inthe computations under TCGA92/S72 and TCGA92/S73.