Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
, see all updates

Absolute entitlement: example: Stephenson v Barclays Bank Trust Co

The facts (simplified) are as follows. Under the will of W, his daughters C D and E were entitled to annuities of £300 a year during widowhood. Subject to the annuities the property was to be held in trust for such of his grandchildren as should reach the age of 21. There were two grandchildren, A and B, who both reached 21 before CGT was introduced in 1965.

In 1969 the trustees, the daughters and the grandchildren entered into a deed under which specific funds should be set aside to meet the annuities and the rest of the property should be paid over to the grandchildren. In fact however the trustees held onto this property.