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HMRC internal manual

Capital Gains Manual

Absolute entitlement: losses of trustees: apportionment

In general any reasonable basis of apportionment adopted by the trustees should be accepted. Losses arising on the actual Section 71 occasion should be allocated to the beneficiary becoming absolutely entitled. Otherwise, unless specific losses relate to particular funds they should be allocated on a broad basis according to the share of the capital going to the beneficiary. There are however no specific provisions for determining which losses brought forward have been set against which gains.