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HMRC internal manual

Capital Gains Manual

Close companies: apportionment: trusts and personal representatives

Where shares are held by

  • trustees of a settlement or
  • personal representatives of a deceased personincome may be apportioned to one or more beneficiaries of the trust or estate. If the shares are subsequently disposed of by the trustees or personal representatives, strictly TCGA92/S124 cannot apply, because it only applies where the disposal of the shares is by the person who was assessed to Income Tax.