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HMRC internal manual

Capital Gains Manual

Charge on beneficiary of non-resident settlement – TCGA92/S87: Matching in a later year - example - the rules for 2008-09 to 2017-18


Trustees’ section 2(2) amount £30,000
Capital payment received beneficiary C £26,000



Unmatched capital payment beneficiary A £5,000


This is a continuation of CG38715.

Section 87 gains

The capital payments received in 2014-15 are matched first against the section 2(2) amount for that year. Chargeable gains of £26,000 accrue to C in 2014-15 leaving an unmatched section 2(2) amount of £4,000.

The balance of the capital payment £5000 received in 2013-14 is matched against this gain. A gain of £4000 is treated as accruing to A in 2014-15. A’s unmatched capital payments received in 2013-14 are reduced to £1,000.