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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Gifts: Inheritance Tax: gifts to settlor-interested settlements: transferee is settlor-interested settlement immediately after disposal

Subject to certain exceptions, hold-over relief under TCGA92/S260 is unavailable where the “relevant disposal” (see CG67068C) is to the trustees of a settlement where, immediately after the disposal

  • the settlement is a “settlor-interested settlement” (see CG67068A), or
  • there is an “arrangement” (see CG67068A) in existence under which the settlement will or may become a settlor-interested settlement.

[TCGA92/S169B (1) and (2)]

The exceptions to this general rule are explained in CG67071.