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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Disposal of interests in settlements: introduction

Therefore it is clear that the tax charge would be very heavy. So the general principle is that the gains or losses of beneficiaries on their interests in settlements are exempt, subject to the exceptions in CG38012 below. A charge to Capital Gains Tax arises when the trustees sell assets, or the beneficiaries become absolutely entitled to the assets, and the charge is on the trustees only.