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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Absolute entitlement: contingencies: date of absolute entitlement

Where settled property is due to pass absolutely to one or more beneficiaries on the happening of a contingency, such as the death or remarriage of a particular individual, the occasion of charge on the trustees under TCGA92/S71 (1) is the date upon which the contingency occurs, even though the trustees may have prior charges to meet.