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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Close companies: apportionment: trusts and personal representatives

ESC/D12By concession (ESC/D12) relief under Section 124 may be given to trustees or personal representatives on the disposal by them of the shares in respect of which an apportionment has been made if

  • income has been apportioned to either a beneficiary of the trust of a residuary beneficiary of the estate, and
  • the tax on that income has been borne by the beneficiary, and
  • the disposal (for Capital Gains Tax purposes) of the shares in question is by the trustees of the settlement or the personal representatives.