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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Absolute entitlement: valuation

Where however, on the exercise of a Power of Appointment etc under a single or successive deeds, two or more beneficiaries each become absolutely entitled as against the trustees to a specified number of shares, the parcels of shares appointed to each beneficiary should be valued separately.

For example, if 50 shares are appointed to A and under the same, or a separate, deed, 50 shares are appointed to B the valuation should be on the basis of two parcels each of 50 shares for the purpose of computing the chargeable gain on the trustees’ deemed disposals of the shares.