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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Non-resident trusts: trustees’ chargeability: Capital Gains Tax

If the trust is non-resident throughout the tax year, the trustees are not chargeable to Capital Gains Tax on any trust gains made in that year. But the settlor or beneficiary may be taxable on capital gains - seeCG38205. External users can find this guidance at

If the trustees are resident for any part of a tax year, gains arising at any time in the tax year are chargeable to Capital Gains Tax. There is no split year treatment. For example, where a UK resident trust becomes non-resident during the year there may be an exit charge (TSEM10270).