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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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TCGA92/Sch4B - deemed disposal of remaining chargeable assets


The charge under Schedule 4B is given by TCGA92/Sch4B/para10. It applies if there is a transfer of value linked with the trustee borrowing; CG39140. The trustees are treated as:

  • disposing of, and
  • immediately reacquiring
  • the whole or part of the ‘remaining chargeable assets’ at their market value.

Whether the deemed disposal is of the whole or part of the remaining chargeable assets depends on how much of the outstanding trustee borrowing has been applied in making the transfer. This is determined by various fractions in TCGA92/Sch4B/para11, CG39190.