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HMRC internal manual

Capital Gains Manual

Separate settlements: intention of trustees

Swires v Renton, L3278, shows that some attention may be given to the intention of thetrustees. However the judge did not accept the Special Commissioner’s view that one couldlook at the subjective view of the trustees in exercising their power. All that could belooked at is what they did and the actual wording of the documentation.