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HMRC internal manual

Capital Gains Manual

Absolute entitlement: distribution of assets not as strict entitlement

Following the occasion of charge under Section 7l(l), when beneficiaries become entitled to the whole of the trust assets, the trustees may distribute the assets to the beneficiaries under a scheme of division otherwise than in accordance with their proportionate shares. In this situation there are good grounds for saying that there is a chargeable disposal by each beneficiary by way of an exchange of assets.

Similarly specific assets may be appropriated by trustees to a beneficiary who has become absolutely entitied to a proportion of the settled property. In this case the exchange is between the trustees and the beneficiary.