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HMRC internal manual

Capital Gains Manual

Absolute entitlement: class closing rules: possible birth of children

In cases of this kind there are three possible dates on which absolute entitlement could be said to have occurred.

  • The date upon which the incapacity arose
  • the date upon which the trustees became aware of the situation, or
  • the date upon which they decided to act on the basis of their knowledge.In the Board’s view the last of these is correct.