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HMRC internal manual

Capital Gains Manual

Absolute entitlement: distribution of assets not as strict entitlement

It is however possible that the principles of Warrington v Brown may be applicable inthese two situations, see CG37410 - CG37411, so that there is no second disposal followingshortly after the Section 71 (1) occasion. If the trustees and beneficiaries seek to applythose principles, no objection should be made, although any attempt to treat a subsequentdisposal of an asset on an inconsistent basis should be resisted.