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HMRC internal manual

Capital Gains Manual

Absolute entitlement: but for being an infant

Where he or she would have become absolutely entitled on or after 3 April 1981, TCGA92/S71(3), (introduced by FA81/S87) makes it clear that there is on that occasion a deemeddisposal by the trustees under Section 71(1), and the beneficiary should therefore betreated as acquiring the assets at market value at that time.