Commentary

I5.1216 Capital gains tax liability of trustees—general

IHT, trusts and estates

I5.1216 Capital gains tax liability of trustees—general

I5.1216 Capital gains tax liability of trustees—general

Non-resident trustees' chargeability to UK CGT

Gains arising at any time in the tax year are chargeable to CGT if the trustees are resident in the UK for any part of the year.

If the trustees are not resident in the UK for the entire tax year they are generally not chargeable to CGT for the year, even on gains arising in the UK1.

The trust cannot split the tax year so, even if the trustees are resident in the UK for just one day, all gains arising in that tax year are chargeable.

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