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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Absolute entitlement: losses of trustees: entitlement on or after 16 June 1999

Under TCGA92/S71 (2C) & (2D), where the trustees have a loss on the occasion of absolute entitlement, that loss is set against available gains, those arising on the same occasion or earlier in the tax year, in priority to any other loss, but solely for the purpose of determining the amount of loss treated as belonging to the beneficiary. This does not affect the way in which the trustees’ losses are set against gains in computing taper relief.