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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Separate settlements: reopening cases

Where the question has been considered and settled previously Inspectors should not seekto disturb an existing treatment as one settlement or several. If the question is raisedby the trustees, then the matter must be looked at critically. Trustees will generally beseeking to change treatment either to obtain a double annual exempt amount or because onesettlement would be chargeable at 35 per cent under TCGA92/S5, see CG35210, and the otherwould not.