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HMRC internal manual

Capital Gains Manual

Dual resident settlements - TCGA92/S87


Section 87 also applies if the trustees are UK resident at some time during the year and at the same time are treated as resident in another country under the terms of a double taxation agreement, TCGA92/S88. Section 87 applies only to those assets which are not liable to UK Capital Gains Tax. Section 88 refers to these as “protected assets”. The trustees themselves are chargeable on any gains on other assets. This is a similar restriction to that which TCGA92/Sch5/para 1(4) applies to TCGA92/S86, see CG38530.