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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Absolute entitlement: purchase of life interest and reversion

Where a person, who has acquired a life interest or remainder in settled property for a consideration in money or money’s worth, subsequently acquires the other interest (also for a consideration in money or money’s worth) and so becomes absolutely entitled as against the trustees to the settled property, there is an `occasion of charge’ on

  • the trustees under TCGA92/S71 (2), and
  • the person who acquired the interest under TCGA92/S76 (2), see CG38040.