»Ê¹ÚÌåÓýapp

TCGA92/S60

A beneficiary is most likely to become absolutely entitled to trust property when they reach an age specified in the trust deed or on the death of a life tenant. See CG37000+ for full guidance on absolute entitlement and TCGA92/S60. As many non-resident settlements are discretionary there may be limited occasions when section 60 applies.

»Ê¹ÚÌåÓýapp ordinary Capital Gains Tax rules apply to the event itself. So if absolute entitlement occurs on the death of the life tenant TCGA92/S73 may apply. »Ê¹ÚÌåÓýapp deemed disposal would not give rise to a gain and the trustees would acquire the property at market value at the date of death. »Ê¹ÚÌåÓýapp capital payment has to be considered entirely separately. »Ê¹ÚÌåÓýapp beneficiary who has become absolutely entitled has received a capital payment and a TCGA/S87 gain will accrue when that payment is matched against section 2(2)* amounts.

*This section was re-written for disposals from 6 April 2019 to section 1(3) see CG10150.