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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Legal background to trusts and estates: personal representatives pay assets to trustees

Personal representatives may assent to assets going to trustees. Trustees and personal representatives may be the same individuals but acting in a different capacity. For capital gains tax purposes, they receive the assets as legatees (CG31140). External customers can find this guidance at

They cannot hold an asset simultaneously in both capacities. But they may hold some assets as personal representatives, at the same time as they hold other assets as trustees.