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HMRC internal manual

Capital Gains Manual

Changes of residence by trustees: exit charge


TCGA92/S80 provides for a deemed disposal and reacquisition at market value when, on or after 19 March 1991, trustees cease to be resident in the United Kingdom. Usually this happens because United Kingdom trustees retire and are replaced by non-residents. HMRC Trusts & Estates deal with any liability under TCGA92/S80. This guidance is given only to help you identify cases to send to them in accordance with CG38400+.


TCGA92/S81 limits or eliminates the charge where the change in residence results from the death of a trustee and former residence status is resumed within six months.


TCGA92/S83 imposes a similar charge when, on or after 19 March 1991, the trustees remain resident in the United Kingdom but become resident in another country as well (`dual-resident’).

The charge

A charge under Section 80 or Section 83 is deemed to arise immediately prior to the change in the trustees’ residence status.

The gain is computed as if the trustees had disposed of, and immediately reacquired at market value, all the assets which fall out of the United Kingdom tax charge on the change in trustees’ residence status.


TCGA92/S80(6) prevents roll-over relief under TCGA92/S152 from applying so as to avoid the new exit charge where trustees dispose of assets before, then acquire new assets after becoming non-resident where the new assets are outside the United Kingdom tax charge.

TCGA92/S84 denies roll-over relief where new assets are acquired on or after 19 March 1991 by dual-resident trustees, the gains on which are outside the United Kingdom Capital Gains Tax charge by virtue of a Double Taxation agreement.