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HMRC internal manual

Capital Gains Manual

Absolute entitlement: effects: deemed disposal

TCGA92/S71 (1)

When a person becomes absolutely entitled to settled property as against the trustee,see CG34320-34321, all that property is deemed to be disposed of by the trustee andimmediately re-acquired by the trustee as `bare trustee’ at market value. Any chargeablegains which arise as a result of this deemed disposal are chargeable gains of the trustee,and the ordinary rules of computation will apply. The cost of acquisition of the assets inthe hands of the beneficiary will be the same market value, and there will be no secondcharge on the trustees if the property is handed over to the beneficiary some time later.