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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Disposal of interests in settlements: introduction

All forms of property, see TCGA92/S21 (1), are assets for the purposes of Capital GainsTax. Therefore in the simple case where there is a settlement with a life tenant A,entitled to the income, and a remainderman B, entitled to the capital on the death of A,the interests of A and B are assets. If they were to dispose of those interests, by givingthem away to their children, or by selling them, if there were no special provision, therewould be a chargeable gain (or exceptionally an allowable loss) on those disposals.