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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Absolute entitlement: but for being an infant

Where he or she would have become absolutely entitled before 3 April 1981, there was on that occasion a deemed disposal by the trustees of those assets under what is now TCGA92/S71 (1) and the beneficiary should be treated as acquiring the assets at their market value at that time. Where, however, in accordance with earlier instructions, the District has accepted that no chargeable gains accrued to the trustees on that occasion because there was no deemed disposal of assets, that position should continue to be accepted but the beneficiary should nevertheless be treated as acquiring the assets at their market value at that time.