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HMRC internal manual

Capital Gains Manual

Absolute entitlement: part of trust fund: other trusts of land

The decision in Crowe v Appleby, 51TC457, is not applicable to all cases in which the trustees of settled property own land. In determining whether the principle at CG37540, which is based on that decision, applies, it is necessary to consider both the location of the land (since the Law of Property Act 1925 applies in England and Wales but not in Scotland or Northern Ireland) and the trust law in the country in which the trust was set up.