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HMRC internal manual

Capital Gains Manual

TCGA92/S90 - all property transferred for nil consideration - example

All the settled property of the transferor settlement is transferred to the transferee settlement for nil consideration in 2012-13. No capital payments have been made out of the transferor settlement. The transferor settlement had the following gains made by the trustees:

2005-06 Trustees’ gains (section 2(2) amount) £20,000
2012-13 Section 2(2) amount on transfer of all settled property £75,000

The transferee settlement acquires these unmatched section 2(2) amounts. They are added to any unmatched section 2(2) amounts it already has for the years 2005-06 and 2012-13. This applies whatever the residence status of the transferee settlement.

The unmatched section 2(2) amounts in the transferor settlement are now reduced to Nil.