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HMRC internal manual

Capital Gains Manual

Disposal of interest in resident settlement: trustees becoming NR

FA81/S88 (2) - (7)

Where a person

  • disposed of an interest in a settlement,
  • on or after 10 March 1981,
  • the gain was exempt under CG38010 above, and
  • the trustees became non-resident subsequently, but before 19 March 1991,

a chargeable gain arose to the trustees immediately before that date equal to the exempt gain, unless all the assets were disposed of in the year of emigration.