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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Separate settlements: introduction

If property was held upon the trusts of one settlement, and is now held upon the trusts of another settlement, then there must have been a disposal within TCGA92/S71 (1), even though the trustees of both are the same persons. This was made clear by Lord Wilberforce in Roome v Edwards, 54TC at page 390H.