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HMRC internal manual

Capital Gains Manual

Absolute entitlement: losses of trustees: hold-over relief

On the deemed disposal of various assets under TCGA92/S71 (1), chargeable gains may accrue on some, and losses may arise on the remainder of the assets to which the beneficiary becomes absolutely entitled. Where claims to hold-over relief are made in respect of some or all of the assets on which chargeable gains accrue, see CG66880+, relief should first be given under that Section and the losses set-off only against such of the gains (if any) as remain chargeable after the grant of hold-over relief.