This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Capital Gains Manual

Absolute entitlement: losses of trustees: entitlement on or after 16 June 1999

This paragraph and the next two apply where absolute entitlement occurs on or after 16 June 1999.On the occasion when a beneficiary becomes absolutely entitled to any settled property as against the trustee, any allowable loss which

  • arises on the deemed disposal by the trustees of assets to which the beneficiary then becomes absolutely entitled, that is, as a result of the operation of TCGA92/S71 (1),


  • cannot be deducted from gains accruing to the trustees on or before that deemed disposal of assets under Section 71(1),is treated as a loss of the beneficiary. Losses so transferred are no longer available to the trustees. See CG15812-15813 about quantifying losses.