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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Separate settlements: substance of the transaction

He then compares two typical cases, the conventional use of a special power ofappointment, which would not normally give rise to a new settlement, and the exercise of apower `to appoint and appropriate a part or portion of the trust property to beneficiariesand to settle it for their benefit.’ In the latter case it would probably be a newsettlement.