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HMRC internal manual

Capital Gains Manual

What is a non-resident settlement?

In this guidance the term non-resident settlement means a settlement in which the trustees are not resident in the UK throughout the tax year. If trustees are resident in the UK for part of the tax year, even one day, they are liable to Capital Gains Tax for the whole year,TCGA92/S2(1A)(c


At 6 April 2014 the trustees of the AB family settlement are all resident in Guernsey. On 3 April 2015 those trustees resign and are replaced by trustees resident in the UK. The residence of the settlement changes from Guernsey to the UK. The trustees are chargeable to Capital Gains Tax on gains accruing at any time during the tax year 2014-15.