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HMRC internal manual

Capital Gains Manual

Absolute entitlement

For Capital Gains Tax purposes, it is necessary to establish when the disposal takes place. If there were no provision in the legislation to cover it, the disposal for CGT purposes would take place when the trustees actually transferred the assets to the beneficiary. This would enable liability in many cases to be postponed, because often the beneficiary would be quite content to let the trustees hold on to the property in question.