Commentary

E1.231 Capital gains tax liability of trustees and personal representatives

Personal and employment tax

E1.231 Capital gains tax liability of trustees and personal representatives

E1.231 Capital gains tax liability of trustees and personal representatives

The capital gains tax legislation governing the liability for tax of trustees and personal representatives provides that tax may be assessed and charged on, and in the name of, any one or more of the relevant trustees or relevant personal representatives, ie those who were trustees or representatives in the year in which the gains accrued and any subsequently appointed1. See I5.1015 (trustees) and I4.534 (personal representatives).

The charge on emigration is not made on a trustee who ceased to be a trustee of the settlement before the

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