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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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TCGA92/S90 - All settled property transferred for a consideration of market value - example

All the settled property of the transferor settlement is transferred to the transferee settlement in 2012-13. The transferee settlement pays market value to the transferor settlement for these assets.

No capital payments have been made out of the transferor settlement. The transferor settlement has 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

These unmatched section 2(2) amounts remain in the transferor settlement and can be matched with future capital payments from that settlement. None of the unmatched section 2(2) amounts are transferred to the transferee settlement.