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HMRC internal manual

Capital Gains Manual

Absolute entitlement: termination after specific period

There are basically two types of case.

a) The first is where the deed or will provides for the property to be shared among a class of people alive on a particular date in equal shares. No one can tell who is to take a share until that date. Therefore absolute entitlement occurs on that date, because until then no one is absolutely entitled.
b) The second is where a prior interest in income is to end on a particular date. There are two beneficiaries, the person entitled to the income and the person entitled to the capital. Their interests are of different kinds; so they are not `jointly absolutely entitled’. After the particular date there is only one beneficiary, who is now absolutely entitled.