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HMRC internal manual

Capital Gains Manual

Absolute entitlement: losses of trustees: entitlement before 16 June 1999

All losses which can be deducted from gains accruing to the trustees on or before the occasion of charge under Section 71(1) must be so set off, without regard to which beneficiary may ultimately become absolutely entitled to particular assets. The transfer of losses to the beneficiary takes place before the gains of the later part of the year are considered.